Resources / International Tax Lunches

International Tax Lunches

August 2016 International Tax Lunch: Taking Your Trust Across the US Tax Border
July 2016 International Tax Lunch: How To Use Nongrantor Trust Structures For Foreign Investment In U.S. Real Estate
May 2016 International Tax Lunch: PFIC Tests in Depth for Operating Companies
April 2016 International Tax Lunch: Tax Planning for Foreign Service Providers with U.S. Clients
October 2016 International Tax Lunch: The Portfolio Interest Exception: All Secrets Revealed
November 2016 International Tax Lunch: Selling Goods Across the US Border
December 2016 International Tax Lunch: Estate Taxation and Expatriation
January 2017 International Tax Lunch: Foreign Mutual Funds and Form 8621 — the Default Rules in Depth
February 2017 International Tax Lunch: Using Foreign Corporations to Defer US Tax on your Foreign Consulting Income
March 2017 International Tax Lunch: How to Report an Accumulation Distribution from a Foreign Nongrantor Trust
April 2017 International Tax Lunch: Reporting PFICs with Insufficient Data
May 2017 International Tax Lunch: Foreign Corporation Investing in U.S. Real Estate Through a LLC
July 2017 International Tax Lunch: Form 8621: Mark-to-Market and QEF Basics
August 2017 International Tax Lunch: Claiming Foreign Tax Credit with a Hybrid Entity
September 2017 International Tax Lunch: Foreign Grantor Trusts
October 2017 International Tax Lunch: Dual Status Returns
November 2017 International Tax Lunch: PFIC Tests In-Depth for Operating Companies
December 2017 International Tax Lunch: Irrevocable Trusts for Real Estate
January 2018 International Tax Lunch: Form 5472 Filing Requirements and Preparation
February 2018 International Tax Lunch: Pensions as Foreign Trusts
March 2018 International Tax Lunch: Treaty Election for Nonresident Status
April 2018 International Tax Lunch: How Foreign Mutual Funds are Taxed and Reported
May 2018 International Tax Lunch: Withholding on Foreign Members of LLCs and Partnerships
June 2018 International Tax Lunch: Taxation of Community Property for Americans Abroad (Section 879)
July 2018 International Tax Lunch: An In-depth Guide to the Certification Test
August 2018 International Tax Lunch: Form 5471 Categories and Attribution Rules
September 2018 International Tax Lunch: Dual-Status Returns
October 2018 International Tax Lunch: The Exit Tax
November 2018 International Tax Lunch: FIRPTA Withholding
December 2018 International Tax Lunch: PFIC to CFC
January 2019 International Tax Lunch: Tax Treaties for Regular People
February 2019 International Tax Lunch: Foreign Ownership of US Property for Personal Use
March 2019 International Tax Lunch: Form 5472 Filing Requirements and Preparation
April 2019 International Tax Lunch: Foreign Earned Income Exclusion and How to Prepare Form 2555
May 2019 International Tax Lunch: Reporting Requirements For A Foreign Corp Holding US Rental Property
July 2019 International Tax Lunch: Accumulation Distribution From A Foreign Nongrantor Trust
September 2019 International Tax Lunch: Guide to Global Intangible Low-Taxed Income
October 2019 International Tax Lunch: Foreign Corporation Information Reporting—Form 5471 and Attribution Rules
November 2019 International Tax Lunch: Dual Status Returns
December 2019 International Tax Lunch: Inbound Executives of Foreign Corporations
January 2020 International Tax Lunch: Expatriation—The Tax Consequences Of Relinquishing US Citizenship
February 2020 International Tax Lunch: Acquisition of U.S. Real Estate by Nonresidents
March 2020 International Tax Lunch: Foreign Owners Of Domestic Corporations And Preparing Form 5472
April 2020 International Tax Lunch: Foreign Earned Income Exclusion
May 2020 International Tax Lunch: Form 5471 – Categories & Attribution Rules
June 2020 International Tax Lunch: Choice of Entity for Foreign Businesses
August 2020 International Tax Lunch: Guide to Global Intangible Low-Taxed Income
September 2020 International Tax Lunch: Section 962 – Should I be Taxed as Corporation?
October 2020 International Tax Lunch: Solving Individual Problems with Tax Treaties
November 2020 International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate
December 2020 International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents
January 2021 International Tax Lunch: Net Worth Test for Expatriation

May 2016 International Tax Lunch: PFIC Tests in Depth for Operating Companies

PFIC Tests in Depth for Operating Companies

The passive foreign investment company (PFIC) rules are mechanical tests. An operating company that is actually doing business can fall afoul of them in the right circumstances. This session discusses some of the circumstances that may make an operating company a PFIC and what to spot to see if they are PFICs.

Presenter: Haoshen Zhong

Materials: Dropbox

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