News & Analysis as of

Income Taxes › PFIC

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Allen Barron, Inc.

Part 2 – International Tax Primer for US Taxpayers and Expatriates

Allen Barron, Inc. on

We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more

Cadwalader, Wickersham & Taft LLP

To Elect or Not to Elect: U.S. Partners May Soon Have to Decide for Themselves Whether to File Passive Foreign Investment Company...

Cadwalader, Wickersham & Taft LLP on

U.S. partners in U.S. partnerships that invest in PFICs may soon be responsible for filing elections previously filed by the partnership. Under current regulations, U.S. partners may rely on entity-level mark-to-market...more

Cadwalader, Wickersham & Taft LLP

Proposed Regs Affect PFIC Elections

Cadwalader, Wickersham & Taft LLP on

On January 25, 2022, the IRS and Treasury proposed regulations that would treat U.S. partners, instead of their partnerships, as PFIC shareholders for making qualified electing fund, mark-to-market, or purging elections,...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Cooley LLP

Blog: Primer - U.S. Tax Considerations for Venture Capital Funds

Cooley LLP on

We are frequently asked by our fund manager clients about what tax issues they should consider when forming a new venture capital fund or investing in portfolio companies. In this post, we outline a few key considerations for...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Alston & Bird

Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed

Alston & Bird on

The IRS and Treasury have proposed the most significant regulations on passive foreign investment companies (PFICs) in nearly 30 years. Our International Tax Group highlights new guidance on fundamental issues and points out...more

Dechert LLP

IRS Releases Proposed Tax Regulations on PFICs, Including Guidance for Foreign Insurance Corporations and Their Investors

Dechert LLP on

The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

Proskauer - Tax Talks on

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

Goulston & Storrs PC

Tax Reform Advisory: International Provisions

Goulston & Storrs PC on

On December 22, 2017, the President signed into law H.R. 1, informally known as the “Tax Cuts and Jobs Act” (the “Act”), implementing sweeping changes to the United States tax regimes generally applicable to businesses. ...more

Proskauer - Tax Talks

House of Representatives and Senate Conferees Reach Agreement on the Tax Cuts and Jobs Act (H.R. 1): Description of the Conference...

Proskauer - Tax Talks on

On Friday, December 15, the U.S. House of Representative and Senate conferees reached agreement on the Tax Cuts and Jobs Act (H.R. 1) (the “Final Bill”), and released legislative text, an explanation, and the Joint Committee...more

Proskauer - Tax Talks

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

Proskauer - Tax Talks on

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 3

Morrison & Foerster LLP on

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

Bilzin Sumberg

Inbound and Outbound U.S. Tax Planning for Bona Fide Residents of Puerto Rico

Bilzin Sumberg on

Since Puerto Rico enacted the “Individual Investors Act” (Act 22) and the “Export Services Act” (Act 20) in 2012, much press has been devoted to the number of high-net worth U.S. taxpayers (including citizens and green card...more

14 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide