H&C's] assets immediately following its election to be disregarded as an entity separate from its owner gives rise to gain that is not foreign personal holding company
income as defined in section 954(c)(1)(B) of the Internal Revenue Code.
Foreign personal holding company
income (FPHCI), including dividends, interest, rents, royalties, and gains from alienation of property that produces or could produce such income;
Foreign Personal Holding Company
income (FPHC income) generally is made up of dividends, interest, royalties, rents, annuities, and gains from the sale or exchange of property that gives rise to such types of income.
However, the contracts may give rise to other types of foreign personal holding company
income, such as income equivalent to interest or the excess of gains over losses from commodities transactions or foreign currency transactions.
7) Income from personal service contracts under [section] 553(a)(5) was formerly a category of the foreign personal holding company
rules, which were repealed as part of the American Jobs Creation Act of 2004.
The bills contain a provision that eliminates the rules applicable to foreign personal holding companies and foreign investment companies, excludes foreign corporations from the application of the personal holding company rules, and includes as subpart F foreign personal holding company
income personal services contract income that is subject to the present-law personal holding company rules.
The act requires the taxable year of a controlled foreign corporation and foreign personal holding company
to be conformed to that of its major U.
954(c)(1) generally defines foreign personal holding company
income (FPHCI), one type of subpart F income, to include the excess of gains over losses from the sale of property giving rise to rents or royalties, other than rents and royalties derived in an active trade or business from an unrelated person (the active rent/royalty exception).
Is not a foreign corporation that meets the stock ownership requirements of a foreign personal holding company
For purposes of PFIC determination, passive income is foreign personal holding company
income (FPHCI) as defined in Sec.