At a Practicing Law Institute seminar in San Francisco on September 22, Douglas Poms, senior counsel, Treasury Office of International Tax Counsel, announced that Treasury expects to issue guidance within the next six months on the passive foreign investment company (PFIC) regime.  According to Poms, the guidance will address whether the same exceptions that apply to foreign personal holding company income under subpart F also apply to passive income under the PFIC regime.  Additionally, the guidance may include modifications to the PFIC related-party look-through rule by applying modified foreign tax credit policies to determine the proper allocation of income between the related parties.  The guidance will also examine foreign companies that separate their passive and active activities into separate subsidiaries and therefore trigger PFIC status, Poms said.