rules apply only to shareholders who are U.
In addition, despite the passive nature of the income, neither the CFC nor the PFIC
rules should apply because the foreign subsidiaries are treated as branches of a Puerto Rican corporation.
49) Thus, it appears that PFIC
and BRIC represent 2 extreme ends of the spectrum of ATP8B1 and ABCB11 disease, respectively.
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
shareholders that would not be required to file Form 8621 under the current instructions to that form may; under Sec.
Under the PFIC
rules, the shareholder owes this extra tax because of the deferral of income.
was designed to provide a more practical means for assessing communication impairment.
The FPHC, CFC, and PFIC
rules all attribute stock owned by a trust to the beneficial owners of the trust.
Construction of the new Palmdale library could begin by late September, with PFIC
providing the final design and construction documents, preparing bid packages and overseeing construction.
If a foreign corporation is characterized as a PFIC
, its U.
Income does not reflect dividends or other income actually received by the Fund, although it does serve to increase the Net Investment Income the Fund is required to distribute.