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FPHC
(redirected from Foreign Personal Holding Company)

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AcronymDefinition
FPHCForeign Personal Holding Company
FPHCFirst Philippine Holdings Corporation (Philippines; private holdings company; est. 1962)
FPHCFrontier Primary Health Care (Pakistan)
FPHCFisher & Paykel Healthcare Corporation Limited (medical equipment; Australia)
FPHCFamily Practice Health Centre
FPHCFlorida Palliative Home Care


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The taxpayer took the position that such gain does not give rise to foreign personal holding company income (FPHCI) within the meaning of Sec.
citizen (UST) to avoid subpart F income and have the ability to repatriate the service fees at qualified dividend income rates, (6) the "personal service contract" provisions in subpart F, which were formerly contained in the foreign personal holding company rules ([subsection] 551 through 558), (7) need to be carefully addressed as well.
In effect, for corporate situations, this change would reintroduce, in a slightly modified form, the reporting that was required until recently from the officers and directors of a foreign personal holding company under section 6035, without reintroducing the income test portion of the definition of a foreign personal holding company.
 
 
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Foreign Policy after September 11 Terrorist Attacks
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