PFICs / Kimberly S. Blanchard
- Foreign income portfolios ; 6300
- Detailed analysis. Introduction -- Overview of the PFIC rules -- Determining PFIC status--[section] 1297 -- Indirect ownership and attribution rules--[section] 1298(a) -- Excess distribution regime--[section] 1291 -- Electing QEF treatment--[section] 1295 -- Income inclusions under the QEF regime--[section] 1293 -- Election to defer payment of tax on undistributed QEF inclusions--[section] 1294 -- Mark-to-market election to include gain or loss from publicly traded PFIC stock--[section] 1296 -- Purging the PFIC taint -- Information reporting requirements -- State and local considerations -- Some suggestions for improving the PFIC rules -- Working Papers.
- " ... discusses the passive foreign investment company (PFIC) provisions. These provisions attempt to deny the benefit of tax deferral to U.S. persons who invest in PFICs, i.e., foreign corporations that generate primarily passive income but whose investors are not subject to the anti-deferral rules for controlled foreign corporations (CFCs)."
- Publication Frequency:
- Updated irregularly
- Authors: Thomas A. O'Donnell and Ozzie A. Schindler, <Oct. 9, 2007>-2012.
Published as: Tax management portfolio 923-2nd, <Oct. 9, 2007>-2012.
Formerly published in Washington, D.C., 2006-2007.
AVAILABLE ONLINE TO AUTHORIZED DICKINSON USERS; PASSWORD REQUIRED FOR ACCESS.
- Bibliography Note:
- Includes bibliographical references.
- Technical Details:
- Mode of access: World Wide Web.
View MARC record | catkey: 19173082