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passive foreign investment company (PFIC)

Proposed Regs Would Clarify When Foreign Insurance Company Income Isn’t PFIC Passive Income

Proposed Regs Would Clarify When Foreign Insurance Company Income Isn’t PFIC Passive Income

Preamble to Prop Reg 04/23/2015; Prop Reg § 1.1297-4   IRS has issued proposed regs that would define several key terms used in determining whether a foreign corporation meets a “passive income test” and qualifies as a passive foreign investment company (PFIC). Specifically, the regs would provide guidance on whether certain investment income earned by […]

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IRS clarifies application of the PFIC look-through rules

IRS clarifies application of the PFIC look-through rules

PLR 201515006   In a private letter ruling (PLR), IRS has clarified the proper application of the look-through rules under the passive foreign investment company (PFIC) regime—specifically, how to determine a foreign corporation’s qualification as a PFIC in a situation where both the subsidiary look-through rule under Code Sec. 1297(c) and the domestic corporation look-through […]

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IRS will amend regs to expand mark-to-market exception to PFIC shareholder reporting

IRS will amend regs to expand mark-to-market exception to PFIC shareholder reporting

Notice 2014-51, 2014-40 IRB In a Notice, IRS has announced that it will amend existing regs to provide that taxpayers whose stock in a passive foreign investment company (PFIC) is marked to market under a Code provision other than Code Sec. 1296 are exempt from the standard reporting requirements that apply to PFIC shareholders. Currently, […]

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U.S. persons owning PFIC stock through tax-exempt organization or account aren’t shareholders

U.S. persons owning PFIC stock through tax-exempt organization or account aren’t shareholders

In Notice 2014-28, 2014-18 IRB, IRS has announced that it will amend the regs under Code Sec. 1291 to provide that a U.S. person that owns stock of a passive foreign investment company (PFIC) through a tax-exempt organization or account will not be treated as a shareholder of the PFIC. Background. A PFIC is any […]

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IRS extends relief in determining PFIC status of foreign banks holding government bonds

IRS extends relief in determining PFIC status of foreign banks holding government bonds

In Notice 2014-31, 2014-20 IRB, IRS has provided a 3-year extension of relief with regard to the treatment of certain government bonds for purposes of determining whether a foreign corporation is a passive foreign investment company (PFIC) under Code Sec. 1297. Solely for this purpose, the income from qualifying government bonds held by an active […]

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Final, temporary & proposed regulations clarify PFIC owner determinations and filing requirements

Final, temporary & proposed regulations clarify PFIC owner determinations and filing requirements

IRS has issued temporary and proposed regs providing guidance on determining ownership of a passive foreign investment company (PFIC) and the annual filing requirements for shareholders of PFICs. The temporary regs, the text of which serves as the text of the proposed regs, generally adopt portions of proposed regs issued in ’92, as revised to […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney