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Tax and reporting rules for Passive Foreign Investment Company can be complicated and confusing. This course reviews how you can determine whether you have a PFIC by applying the PFIC definition, look-through rules and the attribution rules as well as look at the different ways in which PFICs can be taxed, whether under the default rules of IRC Sec. 1291, the Mark-to-Market election or the QEF rules. You will go through some examples of how to perform the calculations and prepare the forms under each of the three methods of taxation and, lastly, you will learn the 'once a PFIC, always a PFIC' rule and the purging elections that may be available if a PFIC is discovered too late.
Tax practitioners advising U.S. taxpayers on foreign tax issues or preparing income tax returns for Americans abroad.
Debra Rudd is a CPA at HodgenLaw PC, a boutique international tax law firm in Pasadena. She has a bachelor’s degree in philosophy from Columbia University and is pursuing a master’s degree in taxation at Golden Gate University.
In addition to managing the firm’s day-to-day operations, she prepares complex tax returns for high net worth individuals and various entities. Focus areas include passive foreign investment companies, controlled foreign corporations, foreign trusts, and foreign investment in U.S. real estate. Russ frequently writes and speaks on various crossborder tax topics for HodgenLaw and CalCPA.