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: Trump Administration eases tariffs on some Canadian agricultural, forestry imports
US President Donald Trump signed an order on 23 October 2026 that removes 50% tariffs on some Canadian agricultural and
Read More
US: SSTGB approves voluntary disclosure programme for remote sellers
US Streamlined Sales Tax Governing Board (SSTGB) approved amendments to the Streamlined Sales and Use Tax Agreement
Read More
US: Trump Administration declares wind turbine imports a national security threat
US President Donald Trump declared that imports of wind turbines and their components threaten US national security on
Read More
US: Trump Says Canada is working hard on a trade deal
US President Donald Trump said on 23 October 2026 that Canada is trying to reach a trade agreement with the US. He made
Read More
US proposes stricter premium tax credit eligibility, repayment rules
The US Internal Revenue Service (IRS) and the Department of the Treasury have issued proposed regulations that update
Read More
US: Gellert Global Group sues to block 50% tariffs on Canadian imports
Gellert Global Group, a US food importer, filed a lawsuit on 20 October 2026 to stop new tariffs on Canadian goods. The
Read More