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.
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