CPA desk with overlapping IRS Form 5471 and Form 8621 documents, foreign holding company model, red caution highlight at the overlap point, and law book referencing IRC 1297(d) overlap rule.

Unreported CFC or PFIC Investments? Streamlined Filing May Help Prevent Double Tax Problems.

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A foreign corporation can be both a Controlled Foreign Corporation (CFC) and a Passive Foreign Investment Company (PFIC) at the same time. Without invoking the overlap exclusion under IRC Section 1297(d), a U.S. shareholder can face double taxation: PFIC excess distribution tax with interest charges on the same income that is also captured by CFC

Unreported CFC or PFIC Investments? Streamlined Filing May Help Prevent Double Tax Problems. Read More »