Are foreign reits PFICs?
R.E.I.T. INCOME AND ASSET TESTS
A foreign corporation is a P.F.I.C. if either (i) 75% or more of its gross income for the tax year is passive income, or (ii) the average percentage of its assets during the tax year which produce or are held for the production of passive in- come is at least 50%.
How do you tell if a stock is a PFIC?
You can generally tell if a foreign corporation or foreign investment fund is considered a passive foreign investment company (PFIC) if it meets one of the following two characteristics: 75% or more of its gross income for the taxable year is passive income, or.
What qualifies as PFIC?
A foreign corporation is a deemed passive foreign investment company (PFIC) if 75% or more of its gross income is from non-business operational activities (the income test), or at least 50% of its average percentage of assets is held for the production of passive income (the asset test).
How are foreign REITs taxed?
Generally, international investors or foreign entities that dispose of shares in a REIT are likely to be subject to US tax on their gain if the REIT is foreign controlled, i.e., if 50% or more of the REIT stock is owned by non-US persons (and the REIT stock is otherwise a USRPI). Gain subject to tax is treated as ECI.
Are all foreign mutual funds PFIC?
The IRS strictly enforces PFIC Rules. Each of Your funds is considered to be a PFIC (Passive Foreign Investment Company). That is because the IRS hates Mutual Funds from overseas — so much so, that foreign mutual funds have been designated as PFICs for tax reporting purposes, which is very bad for tax purposes.
Is Vanguard A PFIC?
Vanguard has chosen to proactively provide Passive Foreign Investment Company (PFIC) annual information statements.
How can I check my PFIC status?
Under the income test, a foreign corporation is a PFIC if 75% or more of its gross income is passive income. Under the asset test, a foreign corporation is a PFIC if 50% or more of the average value of its assets consists of assets that would produce passive income.
Is a foreign bank a PFIC?
A PFIC is any foreign corporation if 75% or more of its gross income for the taxable year consists of pas- sive income, or if 50% or more of the average value of its assets consist of assets that produce, or are held for the production of, passive income. 21 Under Code Sec.
Can a foreign partnership be a PFIC?
Foreign partnerships can be considered PFICs by U.S. reporting standards depending on what type of income they generate. It is very easy not to pay attention to some PFICs that are imbedded in other investments vehicles, i.e. publicly traded partnerships.
Can a publicly traded company be a PFIC?
Generally, a publicly traded foreign corporation will be classified as a PFIC if 50% or more of the average gross value of its assets, determined at the end of each quarter, is attributable to assets such as cash or cash equivalents that produce passive income.