International Tax Lunch: PFIC to CFC—Understanding Filing Requirements and Overlap Webcast | 4183512A


Date :
December 14, 2018 12:00 PM - 1:00 PM
Location :
Facility :
Webcast Remote
Level of Difficulty :
Member Price :
Nonmember Price :
CPE Credits :
CPE 1.00, MCLE 1.00, MCLE LS-TX 1.00
Show tabs

In this presentation, trace the evolution of the U.S. owners' filing requirements with respect to a foreign startup company over the years as more U.S. owners buy in and the total U.S. ownership increases.

Examine the Form 8621 and Form 5471 filing requirements for each year for each of the US individuals involved. Cover how to make a purging election to tax the startup as a CFC (and not a PFIC) in the final year. Finally, briefly discuss the option of making a QEF election for the pre-CFC years.


  • Understanding PFICs and Form 8621 filing requirements
  • Understanding CFCs and and Form 5471 filing requirements

Major Subjects:

  • Form 8621
  • Form 5471
  • PFICs
  • CFCs
  • CFC-PFIC overlap

Advanced Prep:


Misc. Information:

Join or Renew Today

Save with Discount Programs
Level of Difficulty:
Field of Interest:


Designed For:

CPAs and Attorneys.


Debra Rudd, CPA

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.

No Agenda or Materials posted.