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Archive for 'Passive Foreign Investment Company (PFIC)' Category

PFIC Break for Some – No Need to File Annual Form 8621

By Virginia La Torre Jeker J.D., - Monday, January 9, 2017

Heartfelt thanks to Richard S. LeVine, J.D., LL.M. who emailed me to point out that the Internal Revenue Service (IRS) had just recently issued final “Passive Foreign Investment Company” (PFIC)… Read more…

PFIC Rules Can Apply to a Gift?!?

By Virginia La Torre Jeker J.D., - Saturday, April 9, 2016

Part I of this blog post explained that when a US person receives a gift from a foreign corporation or foreign partnership, bad things happen.  Instead of the usual tax… Read more…

OOOOPS! Dad Gave Me A Gift from His Foreign Corporation (or Partnership)

By Virginia La Torre Jeker J.D., - Saturday, April 2, 2016

In my practice in the Middle East I’ve found it very common that families create offshore structures (i.e., outside the USA) in various countries to hold a large portion of… Read more…

Disregarded Entity – Ownership of Foreign Real Property

By Virginia La Torre Jeker J.D., - Thursday, February 11, 2016

Part I of this blog post discussed the general concept of what is called a “disregarded entity”. It also examined how the “disregarded entity” is used (and misused) by non-US… Read more…

PFICs – A Fairytale Definition; Lives Happily Ever After

By Virginia La Torre Jeker J.D., - Monday, February 24, 2014

What is a PFIC? A PFIC is a so-called “Passive Foreign Investment Company” which is defined to include any foreign (non-US) corporation if 75% or more of its gross income for… Read more…

Net Investment Income Tax: 3.8% NIIT, Nit-Picky Nuances for Americans Overseas or With Offshore Investments

By Virginia La Torre Jeker J.D., - Monday, February 3, 2014

If you meet the requirements, your 2013 tax return will reflect the new 3.8% Medicare surcharge imposed on high wage earners. This tax is more commonly called the “Net Investment… Read more…

IRS Gives Good News on PFIC

By Virginia La Torre Jeker J.D., - Monday, January 6, 2014

Creeping up to the New Year, the Internal Revenue Service (“IRS”) showed an uncharacteristic sign of holiday goodwill. On December 30, 2013 the IRS issued Temporary Treasury Regulations providing guidance… Read more…

Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926

By Virginia La Torre Jeker J.D., - Monday, November 4, 2013

Just about everyone reading this blog is aware that the IRS has made international tax enforcement a top priority and that it is attempting to flush out taxpayers hiding assets… Read more…

LATEST IRS NEWS — ANNUAL REPORTING — Foreign Mutual Funds and other “PFIC” Investments

By Virginia La Torre Jeker J.D., - Monday, February 11, 2013

We see many American investors who have invested in foreign (non-US) mutual funds, portfolio bonds and various types of “life insurance” products (the latter are often a fancy version of… Read more…

US Owners of Foreign Corporations – Beware the Downsides Part II

By Virginia La Torre Jeker J.D., - Monday, November 26, 2012

What is a Controlled Foreign Corporation? A foreign corporation is a CFC when more than 50 percent of the voting power or value of its shares is owned by “U.S…. Read more…

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An up-to-date look at US tax laws for American Expats, foreign investors into the US market or other foreign persons having any US connections. More Info

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