TAX 9869 Lecture 12: 20

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11 Aug 2020
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Probs not something anyone wants to own. We see individuals investing and typically they may have inv in foreign hedge funds. Imp to identify which are corps for us tax purposes. Pfic: foreign corporation which earns passive inc (div/int/rent/royalties) Pfic rules refer you back to sub f to determine which items of income are passive. Two tests to determine is it a pfic or not: income or asset test. Income test: if 75% or more of income of foreign corp is passive income, then the fc is a pfic. Take each item of foreign corporation and categorize it. If passive then it goes in here, active there, if passive is 75% or more. Asset test: at least 50% of average assets of foreign corp produce passive income then foreign corp is a pfic; if at least 50% of avg assets produce passive income = pfic. If so, say goes here, if active there.

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