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 ArticleIs 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 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 ArticleLife 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 ArticlePFIC 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 ArticlePFIC 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 ArticleWhat 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 ArticlePFIC 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 ArticleLookthrough 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 ArticleLookthrough 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 ArticleLookthrough 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 ArticleLookthrough 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 ArticleReinvested 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 ArticleIs 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 ArticleShortcuts 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 ArticleAre 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 ArticleReading 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 ArticleWhy 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 ArticleWhat 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 ArticlePFIC 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