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US Treasury issues Final and Proposed Regulations under Section 892 affecting Foreign Government Investors
The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations and new proposed regulations under Section 892 of the Code, significantly clarifying when foreign governments and their controlled entities may claim exemption from US federal income tax on investment income. The guidance is particularly relevant for sovereign wealth funds, central banks, public pension funds, and government-owned investment vehicles investing in US credit, private equity, and real estate structures. [...]