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Upcoming Section 965 Workshop and a Collection of Links
The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces income recognition in the 2017 tax year, so...
View ArticleTaxation of distributions from PFICs in multi-tiered structures
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Foreign life insurance and Americans abroad
Hello again from Phil Hodgen, and Happy 2016. Work here We are hiring. You can see the job listings at hodgen.com/jobs. One admin/office manager, one accountant. That’s what’s on the plate at the...
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PFIC held by a domestic partnership stops being a PFIC
Hey from Debra Rudd. You are receiving this message because you are signed up for our “PFICs Only” mailing list, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. If...
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Is a late MTM election under the inbound immigrant rules possible?
Hello from Debra Rudd. You are receiving this email because you are signed up for our bi-weekly “PFICs Only” newsletter, delivered to your electronic mailbox every other Thursday at 6:00am Pacific...
View ArticleApplying the look through rules to figure out if you have PFIC
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View ArticleHow do losses affect MTM basis and gain recognition?
Hello from Debra Rudd. You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop...
View ArticlePFIC distributions and Net Investment Income Tax
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PFIC deemed sale gains and Net Investment Income Tax
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View ArticleAttribution Rules, Nonresident Alien Spouses, and Controlled Foreign...
This blog post describes a situation when there is an exception in the attribution rules so that one spouse is not considered the owner of the other spouse’s stock in a foreign corporation. This can...
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