David Treitel, tax director, US Tax & Financial Services, said the Passive Foreign Investment Compan...
David Treitel, tax director, US Tax & Financial Services, said the Passive Foreign Investment Company (PFIC) regime is a stumbling block when advising US citizens. The PFIC rule catches any non-US investment fund. It is taxed at the highest US tax rate (35%) when there are excess dividend distributions or stock disposals.
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