Applying The Final Net Investment Income Tax Regulations To ESBTs

In the ESBT context, the Final Regs retain the Proposed Regs’ calculations as they apply to NIIT UNII and MAGI. However, the Final Regs relocated the ESBT provisions from Proposed Reg. §1.1411-3(c)(1) to Reg. §1.1411-3(c) in the Final Regs.