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
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
  • passive foreign investment company
  • entity classification
  • looking through
  • private ruling
Label
IRS scrutinizes PFIC look-through exception
Instantiates
Publication
Label
IRS scrutinizes PFIC look-through exception
Publication

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