The presentation will provide a discussion on some unintended PFIC consequences and some even more unintended ways to make PFICs work for your clients. We will cover an often overlooked pitfall in the QEF election as well as some ways to make the PFIC regulations benefit your client in the right situation.
The presentation will provide a discussion on some unintended PFIC consequences and some even more unintended ways to make PFICs work for your clients. We will cover an often overlooked pitfall in the QEF election as well as some ways to make the PFIC regulations benefit your client in the right situation.
A basic overview of IRC 911 Foreign Earned Income Exclusion covering who can and cannot take advantage of the exclusion, is it always the best option, and some often overlooked nuances to completing Form 2555. Form 2555 will be following by a quick review of other forms that may need to be filed by Americans working or living abroad.
New Features Consolidated Forms Guide Export consolidated tax software grids for Schedule D and Schedule B Form 1040 Statements for consolidated report: Line 21, Additional Tax and Interest, Form 1116…
Expat Tax Tools is pleased to announce the release of our newest calculation module for completing the Form 8621 for Qualified Electing Funds (QEF). The new QEF module includes both…
BY MARY BETH LOUGEN, EA, USTCP
Practitioners that work with clients who have international connections often have to run the gauntlet of Code Secs. 1291–1298, the portion of the statute that covers passive foreign investment companies or PFICs. As someone who frequents the PFIC regulations, I am always in awe of this section of the Internal Revenue Code (“the Code”). The men and women who took the directive provided by Congress in the Tax Reform Act of 1986 and put to paper how we are to treat passive foreign investment companies on a U.S. tax return were geniuses. They have woven an intricate and complex web of “if this, then that” rules that speak to many other sections of the Code—if the PFIC is also a CFC, then … , if the shareholder becomes a U.S. person after already owning an investment that became a PFIC the minute they crossed into U.S. personhood, then … , if the investment was owned prior to 1987 when the regulations came into play, then … . But there is one place where the interaction between the PFIC rules and the rest of the regulations is not in sync, this is the case when there is a sale of a fiscal year qualified electing fund (QEF) during the period between the end of the fiscal reporting year and the taxpayer’s calendar year end.
It is widely thought that QEF election is the best solution to a bad problem— but I am going to have to disagree, or at least disagree when the PFIC reports on a fiscal year.
Update Finalized OVDP calculations including CCH Tax Software entries
Update Desktop to Cloud data transfer scripts
Update CCH Tax Software entry tables updated for 2016.
Fix Foreign tax credit proration removal from joint accounts.
