Avoiding PFIC Status – Practical Considerations
Overview: One area where complexities of U.S. taxation is clearly demonstrated is the Passive Foreign Investment Company (“PFIC”) rules. These PFIC rules generally apply to U.S. investors in a foreign corporation where U.S. ownership is 50% or less. A PFIC is any foreign corporation if – 75 percent or more of the gross income of such corporation for the taxable year [...]