person must file annually, with its federal income tax return for that year, a separate Form 8621, Return by a Shareholder of a Passive Foreign Investment Company
or Qualified Electing Fund, for each PFIC of which the person is a shareholder during the taxable year.
City Bar Ass'n, Report Offering Proposed Guidance Regarding the Passive Foreign Investment Company
Rules, 34-35 (9/21/09)).
Hence, the question arises whether NQPS should be treated as "other than stock" under, for example, section 267, section 1504, or even under the passive foreign investment company
federal income tax purposes, FLY Leasing will be treated as a passive foreign investment company
("PFIC") for 2012 and expects to be treated as a PFIC for the foreseeable future.
Adopt the provision in both bills to eliminate the overlap between the passive foreign investment company
rules and the controlled foreign corporation rules.
international tax regime, the passive foreign investment company
(PFIC) provisions do not coordinate well with the subchapter K partnership rules.
Passive Foreign Investment Company
Rules: Controlled foreign corporations should be exempted from the reach of the PFIC provisions.
Passive income also includes income reported under the foreign personal holding company (FPHC) and passive foreign investment company
(PFIC) rules; see Sec.
In addition, the assets in the trust may be considered "owned" by the employer for purposes of the passive foreign investment company
(PFIC) and (now repealed) section 956A rules.
The memorandum of understanding also provides that Kudelski would disclose that they do not intend to take any actions to transform OpenTV into a passive foreign investment company
and that they would include certain additional disclosures in an amendment to their Schedule TO, including, among other things, detailed information concerning financial analyses that were performed for Kudelski by Credit Suisse concerning the value of OpenTV.
Taxpayers familiar with the passive foreign investment company
(PFIC) provisions are all too aware of just how onerous those rules can be.
Rossi inquired whether an administrability review would have focused greater attention on the redundant compliance burden from the overlapping passive foreign investment company
(PFIC) and CFC regimes.