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Channel: PFIC and CFCs Archives - HodgenLaw PC – International Tax
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PFIC to CFC transition miniseries #2 – Deemed sale election

Hello from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If you would like to unsubscribe from PFICs...

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PFIC to CFC transition miniseries #3 – Deemed dividend election

Hello again from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If you would like to unsubscribe from...

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When a PFIC stops being a PFIC

Greetings from Debra Rudd. You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail Thursday mornings at 6am Pacific Time. To stop receiving...

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Keeping your startup from being treated as a PFIC

Good morning from Haoshen Zhong. You are receiving this message because you are signed up for our PFICs Only newsletter, sent to you every other Thursday morning at 06:00 US Pacific time. To end your...

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Inbound transition rule for MTM election

Greetings from Debra Rudd. You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail every other Thursday morning at 6am Pacific Time. To stop...

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What is my basis in an inherited PFIC?

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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What is the heir’s basis in a PFIC inherited from a NRA?

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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Why is my unit trust a PFIC?

Hello from Haoshen Zhong. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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Upcoming presentations and purging elections

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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What are the reporting requirements for a PFIC held in a US account?

Hello from John Bowlby! You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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Can I give away my PFIC (without paying tax on the gain)?

Hello from Haoshen Zhong. You are getting this email because you subscribed to our “PFICs Only” newsletter, delivered to your inbox every other Thursday at 6:00 am Pacific time. To stop receiving these...

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Taxation of distributions from PFICs in multi-tiered structures

Hi 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...

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Keeping your startup from being treated as a PFIC

Good morning from Haoshen Zhong. You are receiving this message because you are signed up for our PFICs Only newsletter, sent to you every other Thursday morning at 06:00 US Pacific time. To end your...

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Inbound transition rule for MTM election

Greetings from Debra Rudd. You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail every other Thursday morning at 6am Pacific Time. To stop...

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What is my basis in an inherited PFIC?

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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What is the heir’s basis in a PFIC inherited from a NRA?

Hello from Debra Rudd. You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific...

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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...

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Applying the look through rules to figure out if you have PFIC

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...

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