Assertion: foreign investment company | /r/HasProperty | pfic
Facets:
Source sentences:
text: A passive foreign investment company (PFIC) is a corporation, located abroad, which exhibits either one of two conditions, based on either income or assets.
text: A foreign corporation is a deemed passive foreign investment company (PFIC) if (1) 75% or more of its gross income is from non-business operational activities (the income test); or (2) at least 50% of its average percentage of assets is held for the production of passive income (the asset test).
text: For purposes of income tax in the United States, U.S. persons owning shares of a passive foreign investment company (PFIC) may choose between (i) current taxation on the income of the PFIC or (ii) deferral of such income subject to a deemed tax and interest regime.