source income, and does not invest in foreign personal holding companies
or control foreign corporations, neither the trust nor its U.
The rules related to foreign personal holding companies
(FPHC) and foreign investment companies (FIC) have been repealed, and the AJCA makes a number of housekeeping changes to the Subpart F provisions of the IRC to prevent abuses.
The bills contain a provision that eliminates the rules applicable to foreign personal holding companies
and foreign investment companies, excludes foreign corporations from the application of the personal holding company rules, and includes as subpart F foreign personal holding company income personal services contract income that is subject to the present-law personal holding company rules.
The tax applies to all corporations except personal holding companies
, foreign personal holding companies
, exempt organizations and passive foreign investment companies, all of which are subject to special rules.
In addition to individual retail ARS investors, the buy-back offers include non-profit charitable organizations and religious corporations or entities, trusts, corporate trusts, corporations, pension plans, educational institutions, incorporated non-profit organizations, limited liability companies, limited partnerships, non-public companies, partnerships, personal holding companies
and unincorporated associations that made individual ARS purchases and whose account value did not exceed $10 million.
shareholders on income that has not been repatriated: the rules for (1) CFCs, (2) foreign personal holding companies
(FPHCs) and (3) passive foreign investment companies (PFICs).
controlled foreign corporations (CFCs), foreign personal holding companies
(FPHCs) and passive foreign investment companies (PFICs)).
A provision in the Revenue Reconciliation Bill of 1989, now before Congress, requires controlled foreign corporations (CFCs) and foreign personal holding companies
(FPHCs) to conform their taxable years to those of their U.
246(c) holding periods (as modified) and dividends received from certain foreign corporations (foreign personal holding companies
, foreign investment companies and passive foreign investment companies).
163(j)-4 specifies rules on the extent to which interest paid to certain entities (such as controlled foreign corporations, foreign personal holding companies
, and passive foreign investment companies) is considered exempt from U.
The sole shareholders that will hold more than 10% of the Knowlton following the completion of the Acquisition are Rafi Hazan , Michel Ben Soussan, and Elie Hazan, who collectively, through their personal holding companies
identified above, will hold an aggregate of 68% of the common shares of Knowlton (assuming that the performance criteria is met and that a private placement of 1,750,000 common shares of Knowlton at $0.
Schedule A, Part II (Additional Information With Respect to Classes of the Foreign Corporation's Preferred Stock) is a new section that must be completed by foreign personal holding companies