He counsels clients on matters involving controlled foreign corporations, passive foreign investment companies
, effectively connected income, unrelated business taxable income, and income tax treaties.
shareholders of passive foreign investment companies
(PFICs) have created complexity and myriad pitfalls for the unwary investor and tax professional.
To complicate matters further, many foreign pension plans are invested in passive foreign investment companies
(PFIC) and may be subject to the additional filing requirements of Form 8621.
The IRS suspended FATCA (Foreign Account Tax Compliance Act) information reporting requirements for certain individuals with foreign assets and shareholders of passive foreign investment companies
(PFICs) under IRC [section][section] 6038D and 1298(f) (Notice 2011-55).
Under Internal Revenue Code section 904(d)(1)(E), dividends paid by 10/50 corporations that are not passive foreign investment companies
(PFICs) are treated in the aggregate as a separate category of income and are placed in this basket.
7) The term does not include passive foreign investment companies
, foreign investment companies, and foreign personal holding companies.
Those areas identified in 1996 and subsequently addressed by Congress include: overlap of the Controlled Foreign Corporation (CFC) and Passive Foreign Investment Companies
(PFIC); the non-controlled section 902 foreign tax credit basket; the excess passive asset rule in Section 956A and the subpart F treatment of active financial services income.
He regularly provides advice regarding structures for conducting global business and investment activities, establishing foreign holding companies, representative offices, branches and subsidiaries, forming offshore funds, international transfers of assets including intellectual property, and specifically on issues such as Subpart F and passive foreign investment companies
, tax treaties, FIRPTA, foreign tax credits, buy-ins and cost-sharing arrangements and transfer pricing.
1411-10 covers controlled foreign corporations and passive foreign investment companies
He advised both National Office attorneys, IRS field attorneys, and attorneys in the Department of Justice on a broad range of international issues including foreign tax credits, foreign currency issues, subpart F and passive foreign investment companies
, dual resident companies, hybrid financial instruments, partnership allocation issues and many other matters.
Yet another provision applies to passive foreign investment companies
On February 3, 1993, Tax Executives Institute submitted the following comments to the Internal Revenue Service on proposed regulations under sections 1291-1297 of the Internal Revenue Code, relating to passive foreign investment companies