Pfic Corp
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What Is a Passive Foreign Investment Company (PFIC)?
- https://www.investopedia.com/terms/p/pfic.asp
- A passive foreign investment company (PFIC) is a corporation, located abroad, which exhibits either one of two conditions, based on either income or assets: 1. At least 75% of the corporation's gross income is "passive"—that is, derived from investments or other sources not related to regular business … See more
Guidance on Passive Foreign Investment Companies
- https://www.federalregister.gov/documents/2021/01/15/2020-27009/guidance-on-passive-foreign-investment-companies
- This document contains final regulations regarding the determination of whether a foreign corporation is treated as a passive foreign investment company …
United States: Passive foreign investment company …
- https://www.pwc.com/gx/en/services/people-organisation/publications/assets/pwc-united-states-pfic-guidance-provides-new-reporting-exceptions.pdf
- When is a foreign corporation treated as a PFIC? The PFIC regime applies when a US person owns an interest in a foreign corporation that is treated as a PFIC, i.e., if either …
Public Facilities – Developers of Transportation Infrastructure
- https://publicfacilities.com/
- Welcome to Public Facilities Investment Corporation. Public Facilities Investment Corporation (PFIC) specializes in the privatized development and tax-exempt financing …
Instructions for Form 8621 (01/2022) | Internal Revenue …
- https://www.irs.gov/instructions/i8621
- Summary of Annual Information. Who Must Complete Part I. In general, all shareholders …
Passive foreign investment company - Wikipedia
- https://en.wikipedia.org/wiki/Passive_foreign_investment_company
- PFIC status does not, itself, have any impact on the foreign corporation or foreign shareholders. The income test is met if 75% or more of the foreign corporation's gross …
Passive Foreign Investment Companies - The Tax Adviser
- https://www.thetaxadviser.com/issues/2011/oct/clinic-story-04.html
- PFICs are foreign corporations that generate 75% or more of their gross income from passive sources or that own assets that are primarily held for the production of passive …
About Form 8621, Information Return by a Shareholder …
- https://www.irs.gov/forms-pubs/about-form-8621
- About Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund. A U.S. person that is a direct or indirect shareholder …
Your Basic Guide to Passive Foreign Investment …
- https://www.ingletonpartners.com/insights/your-basic-guide-to-passive-foreign-investment-companies-pfics/
- What is a Passive Foreign Investment Company (PFIC)? A passive foreign investment company is an entity treated as a corporation for federal tax purposes, which …
Federal Register :: Guidance on Passive Foreign …
- https://www.federalregister.gov/documents/2022/01/25/2022-00067/guidance-on-passive-foreign-investment-companies-and-controlled-foreign-corporations-held-by
- Pursuant to § 1.1291-9(j)(2)(v), a foreign corporation is a “section 1297(e) PFIC” if it (i) qualifies as a PFIC under section 1297(a) on the first day on which the …
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