Form 5471: What Category Do You Fall Under?

Form 5471: What Category Do You Fall Under?

As mentioned in our previous posts, there are several U.S. tax reporting requirements for our fictional U.S. company “Parent” once it acquires our fictional foreign subsidiary “Sub.” As we discussed in our first post in this series, one of the Parent’s options is to...
PFICs: Dispositions and Purges

PFICs: Dispositions and Purges

For the past few weeks we explored the regulations on Passive Foreign Investment Companies (PFICs), discussed how they are taxed, and examined how certain rules determine ownership and affect reporting requirements. In this post we will discuss the tax impact of...