Passive Foreign Investment Company

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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.
References in periodicals archive ?
The PFIC 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.
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.
Similarly 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.
The PFIC 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.
PFIC 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.