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October 8, 2015 - Debra Rudd

What is the heir’s basis in a PFIC inherited from a NRA?

Hello from Debra Rudd.

You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving this message, scroll down to the bottom and click “unsubscribe”. If you are interested in receiving more of these types of communications, check out our other mailing lists at hodgen.com/lists.

What is the heir’s basis in a PFIC inherited from a NRA?

Last week, I answered a question about a US heir’s basis and holding period in a PFIC that he inherited from a US parent.... continue reading

PFIC and CFCs
September 23, 2015 - Debra Rudd

What is my basis in an inherited PFIC?

Hello from Debra Rudd.

You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving this message, scroll down to the bottom and click “unsubscribe”. If you are interested in receiving more of these types of communications, check out our other mailing lists at hodgen.com/lists.

What is my basis in an inherited PFIC?

Today I will answer the following question:

A US citizen inherited a PFIC from a US citizen parent, and sold it in the same year inherited.

... continue reading
PFIC and CFCs
September 10, 2015 - Debra Rudd

Inbound transition rule for MTM election

Greetings from Debra Rudd.

You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail every other Thursday morning at 6am Pacific Time. To stop receiving these emails, scroll down to the bottom of this message and click “unsubscribe”. If you would like to see what other mailing lists we offer, go to hodgen.com/lists. If you would like to talk to me, hit “reply” to this message and start typing.

Inbound transition rule for MTM election

I received the following question from reader K:

I have client who filed as a nonresident in 2013 and previous years.

... continue reading
PFIC and CFCs
August 13, 2015 - Debra Rudd

When a PFIC stops being a PFIC

Greetings from Debra Rudd.

You are receiving this message because you are signed up for our PFICs Only newsletter, delivered to you via e-mail Thursday mornings at 6am Pacific Time. To stop receiving these emails, scroll down to the bottom of this message and click “unsubscribe”. If you would like to see what other mailing lists we offer, go to hodgen.com/lists. If you would like to talk to me, hit “reply” to this message and start typing.

Schedule change announcement

Effective today, the PFICs Only newsletter will become a bi-weekly newsletter. Everything will be the same, except that you will receive it every other week instead of every week from now on.... continue reading

PFIC and CFCs
August 6, 2015 - Debra Rudd

PFIC to CFC transition miniseries #3 – Deemed dividend election

Hello again from Debra Rudd.

This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If you would like to unsubscribe from PFICs Only, please click the unsubscribe link at the bottom of this message. If you want to check out our other newsletters, please visit hodgen.com/lists.

PFIC to CFC transition miniseries

This week is Part III in a miniseries devoted to examining different aspects of the PFIC rules as they apply to the following scenario:

On January 1, 2010, five individuals create a foreign startup company. Each person owns 20% of the value and voting power of the company.

... continue reading
PFIC and CFCs