a dividend from a PFIC
would be unrelated business taxable income or debt-financed income--see Regs.
The default regime under section 1291 imposes an interest charge on any "excess distributions" (regardless of whether the PFIC
has actual earnings and profits) from the PFIC
foreign tax credits can help shelter Subpart F income and PFIC
shareholder required to report information under See.
Under the PFIC
rules, the shareholder owes this extra tax because of the deferral of income.
owners, however, avoidance of the PFIC
rules has come via an election under Internal Revenue Code Section 953 (d)-to have the company treated as a domestic company-or via Internal Revenue Code Section 1296 (b)(2)(B), which provides that income earned in connection with the active conduct of an insurance business will not be considered as passive income for purposes of the PFIC
To access Aircastle's 2014 PFIC
Annual Information Statement, select the tab "Tax Information (PFIC
)" under the Investors section of the home page of the Aircastle website at www.
LUM001 may reproduce the effects of more invasive surgical procedures for children suffering from PFIC
," said Dr.
As evidenced by the legislative history of the PFIC
provisions and the General Explanation of the Tax Reform Act of 1986 released by the Joint Committee on Taxation (JCS-10-87 at p.
The suspension of the Form 8621 filing requirement applies only to PFIC
shareholders that are not otherwise required to file Form 8621 under the current Form 8621 instructions.
Often, the PFIC
trap can be avoided from the outset by electing one of two alternative methods to tax shareholders who own PFIC
rules, there are a number of significant differences in the approach taken by the two countries.