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
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Beware of the unexpected application of Section 305 to your stock distributions. Our Federal Tax Group serves up examples of useful tools to use.
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