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Prior to the enactment of the PFIC rules, (1) investments in offshore companies (typically hedge funds and mutual funds) were treated like most other investments (i.
Where the employee is not considered the owner of the foreign trust, however, the employee is subject to the filing requirements for PFICs unless no special election has been made for the PFIC and the employee "is not treated as receiving an excess distribution .
taxpayer who owns shares in a Puerto Rican corporation that qualifies for benefits under Act 20 of the Export Services Act generally would not be concerned about the CFC or PFIC rules because income derived from the performance of services in Puerto Rico should not be treated as subpart F income under the CFC rules or passive income under the PFIC rules.
The diagnosis of PFIC is established by a combination of clinical, radiological, laboratory, and biopsy findings.
shareholder with respect to shares of a PFIC held through other entities.
The PFIC rules were enacted in 1986 and generally limit the ability of U.
But the build-up of bile in PFIC causes liver damage.
A PFIC shareholder required to report information under Sec.
However, with a PFIC, there is tax and an interest charge on excess distributions and disposition of the stock.
Bile salt export pump is highly conserved during vertebrate evolution and its expression is inhibited by PFIC type II mutations.
Injury severity was significantly correlated with scores on nine of the 10 PFIC subscales.
A PFIC is characterized by a passive income/assets test (very differently defined than in the FPHC rules), but the stock ownership can be closely or widely held and the percentage of U.
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