Quantcast
Channel: PFIC and CFCs Archives - HodgenLaw PC – International Tax
Browsing all 82 articles
Browse latest View live

Is this a PFIC? Part I: Foreign corporation or not

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

View Article


Is this a PFIC? Part II: Income Test and Asset Test

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

View Article


How 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 Article

Life insurance contracts investing in PFICs

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

View Article

PFIC distributions and Net Investment Income Tax

​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...

View Article


Image may be NSFW.
Clik here to view.

PFIC deemed sale gains and Net Investment Income Tax

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...

View Article

What happens when you set up an IP licensing subsidiary

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

View Article

PFIC Look-through for Foreign Pensions

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

View Article


Lookthrough rules for mutual funds held in nonqualified foreign pensions

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

View Article


Lookthrough Rules for Mutual Funds Held in Foreign Pensions Meeting US...

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

View Article

Lookthrough Rules for Mutual Funds Held in Foreign Pensions in Treaty Countries

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

View Article

Lookthrough of Subsidiary when Subsidiary is Liquidated

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

View Article

Reinvested Dividends from a PFIC

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

View Article


Is my Personal Service Company a PFIC?

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

View Article

Shortcuts We Use to Determine if an Investment is a PFIC

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

View Article


Are Stapled Securities One or More Than One Corporation?

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

View Article

Reading a Profit and Loss Statement for the PFIC Income Test

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

View Article


Why a Holding Company for Active Businesses is Probably Not a PFIC

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

View Article

What is My Basis if I Sell a PFIC Received from a Nonresident Alien as a Gift?

PFIC gifts from a NRA This week’s newsletter topic is from an email from a reader I will call P. What is the basis and holding period of a PFIC received from a nonresident alien as a gift? Today’s post...

View Article

PFIC Wrapper Miniseries #1: Canadian RESP

  This week’s topic is the first of a series of posts that will talk about how various “wrappers” affect the US taxation of PFICs. The particular topic came by way of email: I established a Canadian...

View Article
Browsing all 82 articles
Browse latest View live