Think you know your PFIC status? Think again: application of the look-through rules
The IRS has released Private Letter Ruling 201322009, which responds to a request for clarification on the proper application of certain ‘look-through’ rules for the purposes of determining whether a foreign corporation is a ‘passive foreign investment company’ (PFIC) for US federal income tax purposes. The PFIC rules aim to place US persons that own […]