Whether Treating a Domestic Partnership as an Aggregate Causes Small U.S. Partners to Become Subject to the PFIC Regime
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Whether Treating a Domestic Partnership as an Aggregate Causes Small U.S. Partners to Become Subject to the PFIC Regime
December 13, 2019
Contributor(s)
A foreign corporation can be a controlled foreign corporation (CFC) with respect to some U.S. shareholders and a passive foreign investment company (PFIC) as to other U.S. shareholders. Prior to 1997, it could be both. More from the Weil Tax Blog
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