International Tax: An Overview of PFICs
Author: Patrick McCormick
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
This course will cover the primary rules and guidance associated with passive foreign investment companies (PFICs). Included within the course will be guidance on determining whether a foreign interest qualifies as a PFIC, explicitly focusing on foreign entities classification and determinations regarding passive income levels (even where books and records are unavailable). The course will also review the specific default tax rules applicable to PFICs and where/how they apply. Additionally, the course will also outline alternative elections available for taxing PFIC interests and eligibility requirements, as well as purging options for existing PFIC interests.
Publication Date: May 2023
Topics Covered
- What qualifies as a PFIC
- Default tax rules applicable to PFICs
- Alternative elections available for taxing PFIC interests and eligibility requirements
Learning Objectives
- Identify when a foreign interest triggers the passive foreign investment company rules, with a specific focus on qualifying income/assets and foreign corporate status
- Recognize the default rules regarding PFIC taxation, including applicable interest charges and gain reclassification
- Identify elective alternatives to the default rules for PFIC treatment and requirements to be eligible for elective alterations
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
