persons who are shareholders of a passive foreign investment company
stock in a passive foreign investment company
, then the rules of
Moreover, in determining whether a foreign corporation is a Passive Foreign Investment Company
Transferor of Property to a Foreign Corporation', and 8621, Information Return by a Shareholder of a Passive Foreign Investment Company
or Qualified Electing Fund).
For US federal income tax purposes, FLY Leasing will be treated as a passive foreign investment company
for 2013 and expects to be treated as a PFIC for the foreseeable future.
And in 1997, Congress rectified an inequity that has existed for the past decade when it eliminated the overlap between the controlled foreign corporation and passive foreign investment company
The 1986 act, as modified by the Technical and Miscellaneous Revue Act of 1988, amplified the definition of a controlled foreign corporation by introducing the concept of related person insurance income, introduced the branch profits tax and the passive foreign investment company
and required the discounting of loss reserves and the reduction of the deduction for unearned premium reserves.
Since the enactment of the passive foreign investment company
(PFIC) statutes in 1986, the global economy has undergone a dramatic reorientation toward services and information technology.
M2 EQUITYBITES-March 31, 2014-FLY Leasing plans to stay a 'passive foreign investment company
Aircastle is considered a passive foreign investment Company
for US Federal income tax purposes through 2012 and expects to be treated as a PFIC for the foreseeable future.
(5) Although each of these regimes differ significantly from their equivalent regimes in the United States under the Internal Revenue Code (the Code), the FAPI and FIE/OIFP rules have the same general tax policy objectives as the Subpart F and passive foreign investment company
(PFIC) rules, respectively.
31, 2013, during which (1) the estate or trust owns an interest in a controlled foreign corporation or passive foreign investment company
, and (2) the estate or trust is subject to tax under Sec.