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March 18, 2018 - Phil Hodgen

Upcoming Section 965 Workshop and a Collection of Links

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

American Business Abroad Minimultinationals PFIC and CFCs Speeches, Publications, and Events
May 5, 2016 - Debra Rudd

PFIC deemed sale gains and Net Investment Income Tax

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.​

PFIC deemed sale gains and Net Investment Income Tax

I received the following question from reader S after writing about the Net Investment Income Tax in the context of PFIC distributions:​

Along 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?

... continue reading
PFIC and CFCs
April 21, 2016 - Debra Rudd

PFIC distributions and Net Investment Income Tax

​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.

PFIC distributions and Net Investment Income Tax

​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:

Does the Net Investment Income Tax apply to the entire distribution I receive from my PFIC?

... continue reading
PFIC and CFCs
March 24, 2016 - Debra Rudd

How do losses affect MTM basis and gain recognition?

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.

How do losses affect MTM basis and gain recognition?

This week’s question comes from reader G (lightly edited):

I 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.

... continue reading
PFIC and CFCs
February 11, 2016 - Debra Rudd

Applying the look through rules to figure out if you have 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.

Applying the look through rules to figure out if you have a PFIC

This week I will take a look at the following anonymous question I received:

I have shares in a foreign family holding company which buys shares in various foreign businesses. I am not sure if it is a PFIC.

... continue reading
American Business Abroad PFIC and CFCs