• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

IRS form 8621

International Tax Advisory: The PFIC Regulations Get a Facelift

January 13, 2017 By Edward Tanenbaum and Daniel Reach

Our International Tax Group discusses the new rules found in Treasury’s final regulations on passive foreign investment companies.

Read the full advisory by clicking here.

Filed Under: International Tax Advisory Tagged With: domestic C Corporation, IRS, IRS Form 5471, IRS form 8621, mirror code jurisdiction, non-duplication rule, Notice 2014-28, Notice 2014-51, passive foreign investment company, passive income, PFIC, qualified electing fund, REG-140974-11, S corporations, Section 1291, Section 1296, Section 475(f), T.D. 9650, TD 9806, Treasury

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FBAR FDII Gift cards GILTI international tax IRA IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • PTET Elections: Don’t Let Them “Pass” By Unnoticed in M&A Transactions
  • Post-Roe Issues for Health Plan Sponsors: Navigating the Rapidly Changing Legal Landscape
  • Litigate, Legislate and Repeat: The Delaware Escheat Law Spin Cycle
  • Looking Back at Georgia’s 2022 Legislative Session
  • Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

Archives

Copyright © 2023 · Alston & Bird · All Rights Reserved. Privacy.