In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment company (PFIC) and who is in receipt of an excess distribution. The Notice is to amend the definition of a “shareholder” to exempt any US persons who own stock indirectly in a PFIC through some types of tax-exempt from the requirement to file Form 8621 in respect of those PFICs under Section 1298(f). The scope of the Notice includes PFICs that are owned by individual retirement accounts, individual retirement annuities, qualified pension and deferred compensation plans as set out in Sections 401(a), 403(b) or 457(b), tax-exempt entities (e.g., charities), religious and apostolic organizations, state colleges and universities, and qualified tuition programs. The Notice does not however exempt PFICs owned by charitable remainder trusts as set out in Section 664.
«
US: ATR finds that Obama has proposed 442 tax hikes
Vietnam – Tax Revenue Receipts Increase
»
Related Posts
US: Treasury, IRS clarify stance on OECD’s simplified transfer pricing rules
The US Treasury Department and the Internal Revenue Service (IRS) released Notice 2025-04, “Application of the Simplified and Streamlined Approach under Section 482”, on 18 December 2024, clarifying the US government’s stance on using the
Read MoreUS: President Biden enacts 2023 Tax Relief Act, VETT Act for disaster victims and veterans
The US President Biden has signed The Federal Disaster Tax Relief Act of 2023 (H.R. 5863) and the VSO Equal Tax Treatment Act VETT Act (H.R. 1432) on 12 December 2024. These two bills provide significant tax relief measures to support disaster
Read MoreUS: IRS enhances business tax account (BTA) with new features for corporate officials
The US Internal Revenue (IRS) in a release (FS-2024-31) has announced the expansion of its Business Tax Account (BTA), a convenient online self-service tool, to include C corporations on 12 December 2024. This expansion allows designated
Read MoreUS: Treasury and IRS finalise rules on QBU taxable income and foreign currency gains
The US Department of Treasury and Internal Revenue Service (IRS) has released final and proposed regulations on 11 December 2024 under Section 987. These regulations address the calculation of taxable income or loss and foreign currency gains or
Read MoreUS: Louisiana adopts flat income tax rates, ends corporation franchise tax
The Governor of Louisiana signed multiple tax reform bills into law on 4 December 2024, marking a significant tax reform in the state. The state is determined to eliminate uncompetitive taxes like the franchise and inventory taxes, and broaden tax
Read MoreUS: Rep. Ami Bera leads bipartisan push for Taiwan double taxation relief
The US Representative Ami Bera, M.D. (D-CA-06), Ranking Member of the House Foreign Affairs Subcommittee on the Indo-Pacific and Co-Chair of the Congressional Taiwan Caucus, and Rep. Andy Barr (R-KY-06), Co-Chair of the Congressional Taiwan Caucus
Read More