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...
PFICs: Dispositions and Purges

PFICs: Look-Through Rules

In the previous posts we introduced the passive foreign investment company (PFIC) rules and discussed how they are treated for taxation purposes. We touched on how to determine if a fund is a PFIC and the most common type of PFIC. In this post we’ll describe the...
PFICs: Dispositions and Purges

PFICs: Taxation Methods

In our last post we introduced the complex international tax issues of passive foreign investment companies (PFICs) and gave a brief background on the regulations. In this blog post we’ll briefly discuss the various methods of taxation and how to make certain...