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Passive Foreign Investment Company PFIC

Freeman Law

Revoking a Mark-to-Market Election with Respect to a Foreign Company

Freeman Law on

A taxpayer with shares in a passive foreign investment company (a “PFIC”) may qualify to make either a qualified electing fund (“QEF”) election or an election to apply mark-to-market treatment with respect to marketable...more

Foodman CPAs & Advisors

Does investing in a PFIC make sense given FATCA reporting?

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more

Foodman CPAs & Advisors

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

Proskauer Rose LLP

Final Regulations Released Regarding PFIC Ownership Determination and Annual Reporting Requirements

Proskauer Rose LLP on

On December 27, 2016, the Treasury Department (Treasury) and Internal Revenue Service (IRS) released final regulations regarding the determination of ownership of a passive foreign investment company ("PFIC") and regarding...more

Locke Lord LLP

Locke Lord QuickStudy: Proposed Regulations Issued On Hedge Fund Reinsurance Transactions

Locke Lord LLP on

The Internal Revenue Service (IRS) recently issued proposed regulations addressing what constitutes the “active conduct of an insurance business” for purposes of the passive foreign investment company (PFIC) rules (the...more

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