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The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces income recognition in the 2017 tax year, so there is not a lot of time to figure this one out!
Rufus Rhoades will give a one-hour free workshop on March 23, 2018 at 9:00 am Pacific Time. Register here; it’s free.
I call this a workshop because the intention is for Rufus to talk a bit about the new law, then we will open it up for questions and input. Some of you out there are smart about Section 965, so please share with us.... continue reading
Hi from Debra Rudd.
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I received the following question from reader S after writing about the Net Investment Income Tax in the context of PFIC distributions:
... continue readingAlong the same lines, if you were doing a deemed sale to remove the PFIC taint, would the gain from the sale still be subject to the NIIT?
Hi from Debra Rudd.
You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.
Today I’m going to talk about a question I’ve received from a few different people. This particular version of the question comes from reader X:
... continue readingDoes the Net Investment Income Tax apply to the entire distribution I receive from my PFIC?
Hello from Debra Rudd.
You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.
This week’s question comes from reader G (lightly edited):
... continue readingI bought mutual funds in 2015. I plan to make a mark-to-market election. At the end of 2015 they were down. As an example on one there was a loss of $800 (it wasn’t sold) and I stated the FMV on Dec 31 as $14,500, down from $15,300 adjusted basis.
Hello from Debra Rudd.
You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.
This week I will take a look at the following anonymous question I received:
... continue readingI have shares in a foreign family holding company which buys shares in various foreign businesses. I am not sure if it is a PFIC.
