International Tax Lunch: PFIC Tests In-Depth for Operating Companies Webcast | 4173345A


Date :
November 10, 2017 12:00 PM - 1:00 PM
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Webcast Event
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CPE Credits :
CPE 1.00, MCLE 1.00, IRS-TX 1.00, CTEC-TX 1.00
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When U.S. ownership of a foreign corporation is—at most—50%, the foreign corporation, though an operating business, may fall under a special, punitive classification called passive foreign investment company. Learn in depth how to analyze the foreign corporation's income and assets to determine whether the foreign corporation is—or is at risk of becoming—a PFIC.

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Materials are provided as an ebook for this course.


  • Determine the default classification of foreign business entities.
  • Apply the PFIC income test and asset test to a company that offers services through an automated website.
  • Apply the PFIC income test and asset test to a professional service company.
  • Recognize when a controlled foreign corporation-PFIC overlap rule can be used to avoid PFIC classification.

Major Subjects:

  • Default classification of foreign entities
  • Definition of income test and asset test
  • Web company
  • Professional service firm
  • Controlled foreign corporation-PFIC overlap

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Designed For:

CPAs and attorneys.


Haoshen Zhong, Esq.

Haoshen Zhong is a lawyer working at HodgenLaw PC, where he works with CPAs in the firm to identify and classify unusual foreign assets. He is commonly asked to examine hair-splitting regulations and areas where the IRS has published scant guidance, then come to a conclusion about how to treat a foreign asset. He first worked with PFICs in the context of foreign insurance plans and from there expanded into other matters related to them. Zhong received his juris doctor degree from U.C. Hastings. Before joining HodgenLaw, he was a patent agent.

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