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PFIC REPORTING ON FORM 8621

We briefly review the rules of PFIC taxation with an emphasis on the reporting required on IRS Form 8621.

GILTI TAX FOR OWNERS OF FOREIGN COMPANIES

Treasury and the IRS have significantly narrowed the scope of the GILTI tax, by adding a provision which excludes income of a CFC that is subject to “high tax” in the foreign company’s country of incorporation.

GILTI TAX FOR INDIVIDUAL OWNERS OF FOREIGN COMPANIES

In regulations proposed just this week, Treasury and the IRS have significantly eased the pain of the GILTI tax for individuals, by adding a provision which allows individuals to utilize the new 50% deduction against GILTI when making a so-called “962 election.”
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