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Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption

02.10.2026 | Duration: 114:14

Reviewing the practical implications of section 892 and its recently issued regulations

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Section 892 plays a pivotal role in shaping how sovereign wealth funds and foreign government pension funds participate in U.S. markets. How do regulatory developments reshape the landscape for global capital flowing into U.S. markets? What practical considerations should asset managers and fund sponsors keep in mind when working with sovereign investors? For U.S. companies seeking sovereign capital, what new opportunities and challenges lie ahead—especially in structuring direct investments or joint ventures? As sovereign investors refine their approaches and adapt to shifting priorities, will section 892 continue to support robust international investment, or are new dynamics on the horizon that could alter the competitive balance for U.S. markets?

Join us as our hosts Gary Scanlon and Kristen Gamboa interview Dan Winnick, a Principal in the KPMG WNT - International Tax practice, and Kirstin Gallagher, a Principal in the KPMG International Tax – Financial Services Group and US Tax Leader for Sovereign Wealth & Pension Funds, to answer these questions and more on the latest episode of Inside International Tax.

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