The Resource IRS scrutinizes PFIC look-through exception

IRS scrutinizes PFIC look-through exception

Label
IRS scrutinizes PFIC look-through exception
Title
IRS scrutinizes PFIC look-through exception
Creator
Subject
Language
  • eng
  • eng
Summary
In private letter ruling (PLR) 201515006, the IRS National Office, as it previously did in PLR 201322009, suggested that it would insist that certain non-tax-avoidance indicia exist as a condition for favourably ruling that a foreign corporation seeking to avoid passive foreign investment company (PFIC) classification could utilize 1298(b)(7) to treat, as a nonpassive asset, the stock of a secondtier U.S. subsidiary with significant passive income and assets
Citation source
In: Tax management international journal. - Arlington. - Vol. 44 (2015),
http://library.link/vocab/creatorName
Lederman, A.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • PFIC
  • entity classification
  • looking through
  • private ruling

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