Forms 5471 and 8621 on a desk with a model of a foreign holding company, highlighting U.S. tax compliance for Controlled Foreign Corporations and Passive Foreign Investment Companies.

Resolving CFC and PFIC Overlap: Avoiding Double Taxation

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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 »