25 September 2025

Andersen Managing Director Joe Calianno’s article Pop-Up PFICs and Other Issues Raised by the OBBBA is featured in Tax Notes International. In the article, Joe examines the reinstatement of Sec. 958(b)(4) by the One Big Beautiful Bill Act (OBBBA) of 2025. He points out that while it may be good for certain owners of foreign corporations, taxpayers should still be wary of some resulting issues.