Unit Trust in Stapled Security Arrangements
This is a question sent to us through email: I invested in Australian stapled securities. Do I have a PFIC problem? In this post, I will introduce the concept of stapled securities and go through the...
View ArticleCustomer Deposit in a Chinese Investment Firm under the PFIC Asset Test
Cash held for customers This is a war story from client work: I own shares of a Chinese investment firm. The firm’s balance sheet, produced under Chinese accounting standards, shows cash of $X, with...
View ArticleForeign Tax Credit on Sale of a PFIC
This is a question that sometimes comes in an email: I am a US citizen living abroad. I sold a PFIC. I paid foreign tax on the gain. Can I use the foreign tax as a foreign tax credit? We do not have a...
View ArticleCash Distribution from a Mark-to-Market PFIC Stock
Distributions from a PFIC under a mark-to-market election This is a question we received through an email: I own stock of a PFIC. I made a mark-to-market election for the PFIC stock. The PFIC made a...
View ArticleDistributions from a PFIC under a QEF Election
This is a question we received through an email: I own stock of a PFIC. I made a qualified electing fund election for the PFIC stock. The QEF received a distribution of qualified dividends during the...
View ArticlePre-1997 Unit Trust Funds
Pre-1997 unit trusts This scenario is loosely based on some analysis we did for a client: I bought 10% of units in a private unit trust in a foreign country back in 1990. All other unit holders are...
View ArticleForeign Mutual Funds Investing in the US Are Still PFICs
Foreign mutual funds investing in the US This is a question from an email: I have a foreign mutual fund that invests in stocks of US corporations. Is the mutual fund a PFIC? In this post, I will...
View ArticleQEF Election for a Fiscal Year Company in the Year of Immigration
This is a war story: I have owned shares of a foreign company that rents out a warehouse for years. It operates on a fiscal year ending 31 March, 2017. I immigrated to the US on 1 February, 2017. I...
View ArticleTax Cuts on PFICs: Not Much Changed
Effect of the tax cut on PFICs These are some notes I took about how the tax cut affects passive foreign investment companies (PFICs)–or does not affect PFICs. The short answer is that not much...
View ArticleActive Rental Income Exception to Passive Income
Active rental income This is a question we received through an email: I own stock of a foreign real estate investment trust (REIT). It is a corporation under US tax law. It owns a hotel and rents rooms...
View ArticleTax Law Changes Made a CFC-PFIC Overlap Easier
This post notes a change in the way controlled foreign corporation (CFC) rules work now that the newly passed tax law is in effect. This change makes it more likely that a person would fall under the...
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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 ArticleUpcoming 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...
View ArticleTaxation 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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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
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 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
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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