Adverse consequences to U.S. shareholders of PFICs. : An article from: The Tax Adviser
Adverse consequences to U.S. shareholders of PFICs. : An article from: The Tax Adviser
Adverse consequences to U.S. shareholders of PFICs. : An article from: The Tax Adviser
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This digital document is an article from The Tax Adviser, published by American Institute of CPA’s on March 1, 1994. The length of the article is 791 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: US shareholders of companies considered passive foreign investment companies (PFICs) can be subject to harsh tax effects on the dividends they receive, but may be able to mitigate the effects through a deemed sale and the election of qualified electing fund treatment. PFICs have certain percentages of income derived from passive activity and are distinguished from controlled foreign investments. PFIC income is taxed on distribution, and excess distribution can result in interest charges deemed to have started many years before dividends were distributed. PFICs are also denied the benefits of tax-free exchanges and capital gains treatment.
Citation Details
Title: Adverse consequences to U.S. shareholders of PFICs. (passive foreign investment companies)
Author: Gary Melcher
Publication: The Tax Adviser (Magazine/Journal)
Date: March 1, 1994
Publisher: American Institute of CPA’s
Volume: 25 Issue: n3 Page: 142(3)
Distributed by Thomson Gale
Adverse consequences to U.S. shareholders of PFICs. : An article from: The Tax Adviser
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