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https://www.federalregister.gov/documents/2019/07/11/2019-12030/guidance-on-passive-foreign-investment-companies
Thus, if a Tested Foreign Corporation would qualify as a PFIC if section 1298(b)(7) did not apply, either because section 1297(c) applied to treat the Tested Foreign Corporation as owning directly the assets of a domestic corporation in which it indirectly held qualified stock, or because the qualified stock was treated as a passive asset, then ...
https://www.federalregister.gov/documents/2021/01/15/2020-27009/guidance-on-passive-foreign-investment-companies
Section 1297(d) provides that, for PFIC purposes, a corporation shall not be treated as a PFIC with respect to a shareholder during the qualified portion of such shareholder's holding period with respect to stock in such corporation during which time the corporation is a CFC (“PFIC/CFC overlap rule”).
https://www.publicfacilities.com/
Developers of Public Facilities and Infrastructure. Public Facilities Investment Corporation (PFIC) specializes in the privatized development and tax-exempt financing of facilities and infrastructure for the public and non-profit sectors. Since 1969, PFIC has completed over 200 projects in 96 cities in 36 states.
https://home.kpmg/us/en/home/insights/2021/01/tnf-final-and-proposed-regulations-passive-foreign-investment-company-rules.html
The final regulations [PDF 496 KB] (64 pages as published in the Federal Register on January 15, 2021) under sections 1291, 1297, and 1298 address the determination of whether a foreign corporation is treated as a PFIC and the application and scope of certain rules to determine whether a United States person that indirectly holds stock in a PFIC is treated as a …
https://www.irs.gov/instructions/i8621
Passive Foreign Investment Company (PFIC) A foreign corporation is a PFIC if it meets either the income or asset test described next. Income test. 75% or more of the corporation's gross income for its tax year is passive income (as defined in section 1297(b)).
https://www.cpajournal.com/2019/02/06/the-perils-and-pitfalls-of-passive-foreign-investment-company-ownership/
Internal Revenue Code (IRC) sections 1291–1298 contain the federal income tax provisions pertaining to PFICs. IRC section 1297 (a) defines a PFIC as any foreign corporation if either—. 75% or more of its gross income for the taxable year is passive income (the 75% test), or. the average percentage of assets held during the taxable year that ...
https://www.pwc.com/gx/en/services/people-organisation/publications/assets/pwc-united-states-pfic-guidance-provides-new-reporting-exceptions.pdf
When is a foreign corporation treated as a PFIC? The PFIC regime applies when a US person owns an interest in a foreign corporation that is treated as a PFIC, i.e., if either the 50 percent asset test or 75 percent income test is satisfied. Under the income test, a foreign corporation is treated as a PFIC if 75 percent or more of its gross income
https://www.goldinglawyers.com/pfic-cfc-overlap-irs-foreign-company-filing-requirements/
How PFIC/CFC Overlap Can Impact Tax & Reporting: A PFIC i s a Passive Foreign Investment Company (PFIC) and a CFC is a Controlled Foreign Corporation (CFC). Each of these types of entities are IRS legal constructs that result in additional tax and reporting requirements involving: Subpart F, GILTI and excess distributions. The resulting tax and reporting can be very …
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You may also contact our Customer Care representatives at 855-690-5900. We are available to assist you Monday through Friday from 8 a.m. to 10 p.m., and Saturday from 9 a.m. to 6 p.m. Eastern Time. You may also send a fax at (866) 505-0948 or …
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