Personal Holding Company


Also found in: Acronyms.

Personal Holding Company

A corporation in which five or fewer persons control at least half of the company's stock and in which at least 60% of the company's income is passive income from companies it owns. Because personal holding companies may be used by the persons who control them to avoid personal taxes, the U.S. tax system imposes a 15% tax on personal holding company profits in addition to corporate taxes.
References in periodicals archive ?
corporate bonds, and neither the accumulated earnings tax nor the personal holding company tax would typically apply as well.
the flat tax, the accumulated earnings tax and the personal holding company tax.
Foreign personal holding company income (FPHCI), including dividends, interest, rents, royalties, and gains from alienation of property that produces or could produce such income;
A personal holding company exists when more than 50 percent of a corporation's outstanding stock is owned by 5 or fewer individuals, directly or indirectly, and 60 percent of the corporation's adjusted ordinary gross income is personal holding company income.
citizen (UST) to avoid subpart F income and have the ability to repatriate the service fees at qualified dividend income rates, (6) the "personal service contract" provisions in subpart F, which were formerly contained in the foreign personal holding company rules ([subsection] 551 through 558), (7) need to be carefully addressed as well.
A personal holding company is a corporation that meets two particular tests (and is not specifically excluded from such status).
Section 541 imposes an additional corporate-level tax on undistributed personal holding company income (UPHCI)--for example, passive income such as interest, dividends, royalties and sometimes rent income.
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.
S persons, each of whom owns at least 10 percent directly or indirectly), or a Foreign Personal Holding Company (FPHCO), some or all of the deemed asset sale gain could be Subpart F or FPHCO income.
This means that Berlusconi's personal holding company Fin-invest, which still owns a stake of about 50% in Mediaset, will cash in about $100 million in dividends.
Since the Tax Reform Act of 1986 (TRA 86) repealed the General Utilities doctrine, it has become more attractive to retain a liquidated corporation as a personal holding company (PHC).
becoming subject to personal holding company tax for federal income tax purposes for 2005.

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