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Category Archives: PFIC

Is Income from Passive Foreign Investment Corporations Gross Income?

PFIC US Taxation

The Tax Court’s decision in Toso v. Commissioner, was a mixed bag for taxpayers as it relates to Passive Foreign Investment Corporations (PFICs).  The taxpayer argued that for purposes of extending the statute of limitations for assessment from 3 to 6 years under section 6501(e)(1)(A)(i) income taxed under section 1291 was not part of “gross…

September 19, 2018
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  • (2)Controlled Foreign Corporation
  • (34)FATCA
  • (31)FBAR
  • (1)Foreign Earned Income Exclusion
  • (2)Foreign Tax Credits
  • (3)Intellectual Property
  • (30)International Business
  • (49)IRS News & Regulations
  • (2)Limited Liability Companies
  • (4)OVDP
  • (1)PFIC
  • (15)Shipping Taxation
  • (3)Streamlined Foreign Offshore Procedures
  • (1)Uncategorized
  • (27)US citizenship
  • (7)US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES
  • (49)US Taxation
  • (39)US Taxes for Non-Residents
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