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By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide | Never filed Form 8621 for a
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide | A PFIC can be taxed three
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide The excess distribution regime under Section 1291
Do you have to file Form 8621? Not always. The de minimis exception lets you skip the yearly PFIC report if
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide | If you moved to the U.S.
Are foreign ETFs PFICs? Almost always, yes. An ETF organized outside the United States, including the Irish-domiciled UCITS ETFs common in
A CFC and a PFIC are two separate sets of U.S. tax rules for foreign corporations. A CFC is about control:
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide | Is your foreign mutual fund a
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide | You must file Form 8621 if
The PFIC asset test asks whether, on average across the year, at least 50% of a foreign corporation’s assets are passive,
By Edward Parsons, CPA | Ed Parsons CPA, Doral, Florida | Representing taxpayers nationwide The PFIC income test asks one question:
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By Ed Parsons, CPA [Updated May 2026] Short answer: A CPA-led Kwong penalty review should start with
Kwong Protective Claims, Form 843, and IRS Transcript Review By Ed Parsons, CPA [Updated May 2026] Short
By Ed Parsons, CPA [Updated May 2026] Short answer: Kwong is a recent federal court decision that
Form 8858 reports U.S. ownership and operation of Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs) to
A foreign corporation can be both a Controlled Foreign Corporation (CFC) and a Passive Foreign Investment Company
IRC Section 6038(b) imposes an automatic $10,000 penalty for each annual accounting period a U.S. person fails
Subpart F income (passive and certain other categories of CFC income) is taxed to U.S. shareholders in
GILTI (Global Intangible Low-Taxed Income), renamed NCTI under the 2026 One Big Beautiful Bill Act, taxes U.S.
Schedule J of Form 5471 tracks a Controlled Foreign Corporation’s accumulated earnings and profits (E&P) and previously
