Tag Archives: Income and Asset Test

Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed

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Our International Tax Group highlights new guidance on fundamental issues and points out a few sources of potential headache for taxpayers in response to the IRS and Treasury proposing the most significant regulations on passive foreign investment companies (PFICs) in nearly 30 years. Clarifications for the Income and Asset Tests Updates to the PFIC exceptions and look-through rules PFIC stock attribution Read the full advisory here. [...]Read more