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Passive Foreign Investment Company ("PFIC")


Certain U.S. persons may become subject to the PFIC taxing regime if they own an interest in a foreign corporation that invests primarily in passive investments such as ownership of a mutual fund. The PFIC taxing regime is complex and often overlooked. U.S. persons owning shares of a passive foreign investment company may choose between current taxation on the income of the PFIC or deferral of such income subject to a deemed tax and interest regime. We can assist in determining whether you have an interest in a PFIC and the best strategy for minimizing the impact of PFICs on your U.S. tax liability.


Elisa Fay


Partner-in-Charge Rödl National Tax

+1 404 525 2600

Send inquiry


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