Search Results for: pfic
Small PFIC Exception to Filing Form 8621
…for joint filers); or The PFIC shareholder owns the PFIC (e.g., PFIC1) through another PFIC (e.g., PFIC2) and the value of the PFIC shareholder’s proportionate interest in PFIC2 through PFIC1…
Watch Out for PFIC Status
…as a disregarded entity or a partnership is not a PFIC. What Are the Implications of the PFIC Rules? The consequences of owning a PFIC are severe. The IRS estimates…
What is a Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC)?
Several clients have recently asked us about the Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC). A MTM election for a Passive Foreign Investment Company (PFIC) is an…
Foreign mutual funds = Passive Foreign Investment Companies (PFICs)?
…as passive income, nearly all overseas mutual funds are PFICs. A foreign mutual fund might escape classification as a PFIC if a majority of its holdings consists of large shares…
An exception to PFICs in Foreign Pension Plan Accounts
…on determining the ownership of a PFIC and on certain reporting obligations of PFIC shareholders. One helpful aspect of the newly finalized PFIC regulations is that the exceptions to PFIC…
ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…Passive Foreign Investment Company (“PFIC”) rules of sections 1291-1298. One of the goals of the PFIC rules is generally to eliminate any advantage of holding foreign-based mutual funds over holding…
Passive Foreign Investment Company Tax & Mark-to-Market (MTM) election
A PFIC is a passive foreign investment company. One of the most common types of PFIC is ownership of a foreign mutual fund. Our office has worked with clients from…
US Tax Implications of Foreign Life Insurance
…ownership interest in the insurance company itself. If so, the owner may be treated as owning a PFIC. The ownership of a PFIC by a U.S. individual may result in…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…exceptions apply, the PFIC rules are designed to penalize U.S. taxpayers on “excess distributions” from a PFIC or upon a disposition of PFIC stock, imposing the highest ordinary income rates…
Checklist of tax forms for taxpayers with foreign assets
…rather than sent separately to the Department of Treasury. Form 8621: Information Return for Passive Foreign Investment Company (PFIC) — If you own shares in a Passive Foreign Investment Company,…
Do You Have to Pay US Taxes on Foreign Inheritance?
…(PFICs). It is not a violation of U.S. tax law to own a foreign fund classified as a PFIC, but complicated and ongoing annual reporting is required, even if no…
New offshore account disclosure law
…does not begin to run until the taxpayer files the information return disclosing the taxpayer’s reportable foreign assets. Other disclosure provisions New reporting rule for PFICs. Effective on the new…
Full Analysis of Updated 2012 OVDP Program
…and 51.3); an alternative resolution method for reporting PFIC income (FAQ 7); whether penalties will be owed on funds transferred from one unreported foreign account to another during the voluntary…
Beware of Overlooked Common Overseas Tax Forms
…mutual funds and ETFs are classified as PFICS. Each PFIC you own is reported on a separate Form 8621. Other forms that could also apply to your situation include Form…
Common Issues for US-India Tax Reporting
…on the foreign facilitators hotlist. Indian Mutual Funds require PFIC computations using Form 8621. We treat EPFs as employee trusts. This means they need special treatment under IRC 402(b) and…
New Webinar: An Introduction to the Taxation of Passive Foreign Investment Companies
Event Details May 9, 2022 3:00 pm to 4:00 pm Many investors unknowingly invest in Passive Foreign Investment Companies (PFICs) and as a result must file IRS Form 8621, Information Return…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
…foreign investment company (PFIC) issues; eligibility for the 2011 OVDI, including information for those taxpayers who may have previously filed a “quiet” disclosure; the 2011 OVDI process; calculating the offshore…
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…2009 and the new 2011 FAQs seem to resolve some of the issues that arose during the 2009 voluntary disclosure process. For instance, the PFIC issue is now set forth…