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Passive Foreign Investment Company

   Also found in: Acronyms, Wikipedia 0.01 sec.
Passive Foreign Investment Company
A company based in a foreign country where either at least 75% of its income comes from passive sources, such as rent or dividend, or at least 50% of its assets carry dividends or interest. PFICs are subject to strict tax guidelines in the United States that intend to discourage investment by Americans. See also: Income test, Asset test.
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17) PFIC status for start-up and liquidation years: A form of foreign entity not discussed previously is a passive foreign investment company (PFIC), which is essentially a foreign mutual fund.
Tips for preparing the Form 5471 for controlled foreign corporations by Jacobs, Vernon K.; Pasmanik, Philip T. / The Tax Adviser
Overall, since the anti-deferral rules (Subpart F and Passive Foreign Investment Company [PFIC]) will be retained, it is not clear that the dividend exemption proposal is a significant move toward simplification.
Comment on Yin, reforming the taxation of foreign direct investment ... by Avi-Yonah, Reuven S. / Virginia Tax Review
investors will also need to consider the passive foreign investment company (PFIC) rules.
Tax considerations fan the private equity boom: amid much publicity ... by Conway, Kevin / Financial Executive
 
 
 
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