1. At least 75% of the corporation's income is considered "passive", which is based on investments rather than standard operating business.
2. At least 50% of the company's assets are investments that produce interest, dividends and/or capital gains
PFICs include foreign-based mutual funds, partnerships and other pooled investment vehicles that have at least one U.S. shareholder. Most investors in PFICs must pay income tax on all distributions and appreciated share values, regardless of whether capital gains tax rates would normally apply.
|||PFICs are subject to complicated and strict tax guidelines by the Internal Revenue Service , which covers treatment of these investments in Sections 1291 through 1297 of the income tax code. Both the PFIC and the shareholder must keep accurate records of all transactions, including share basis, dividends and any undistributed income earned by the company.
The strict guidelines are set up to discourage ownership of PFICs by U.S. investors. PFIC shares won't even receive a step-up in cost basis as is the case with nearly all other marketable, appreciable assets. An option that investors have is to seek qualification of a PFIC investment as a qualified electing fund . This may reduce the tax rate on certain transactions but also forces the investor to pay taxes even on income earned by the foreign company that is not distributed to shareholders.
深圳投融网商务有限公司是一家专注企业投融资与上市服务的专业机构。公司团队来自国内外的投行精英，具备丰富的国内外的投资银行从业经验，拥有丰富的金融、财务、管理、审计、法律等专业知识与上市辅导经验。
投融网（www.ipo.hk）创建于2011年，拥有300万+俱乐部成员，涵盖银行、券商、信托、政府平台公司、上市公司、拟上市公司、融资租赁公司、商业保理公司、公募基金、私募基金、风险投资机构、天使投资机构、律师事务所、会计师事务所、评估机构、新闻媒体、高净值个人投资者等。秉承链接、赋能、共赢的经营理念，构建了高效的投融资与上市服务生态圈。
欢迎各类机构洽谈合作。
邮箱：service@ipo.hk
电话：0755-33572246
