
PFICs and Foreign Assets
Passive foreign investment company (PFIC) rules and foreign asset reporting requirements can create complex tax and compliance issues for U.S. persons with foreign investments.
Format
Online
NASBA Field of Study
Taxes
Level
Intermediate
CPE Credits
3
Author(s)
AICPA staff
Availability
1 year
Product Number
USITPFA26SSO
Understanding PFIC exposure
PFIC rules can apply broadly to foreign corporations, even when a U.S. shareholder owns only a small interest. Learners will learn about the income and asset tests used to identify PFICs and understand how passive income, passive assets, look-through rules, and annual status determinations affect classification.
Comparing PFIC tax regimes
Learners will examine the default excess distribution regime and compare it with the qualified electing fund (QEF) and mark-to-market (MTM) regimes. Learners will also cover how elections are made, when they apply, and why timely reporting and access to PFIC information can materially affect the tax result for U.S. shareholders.
Managing foreign asset reporting requirements
Foreign asset reporting obligations are covered, including:
- Form 8621
- Report of Foreign Bank and Financial Accounts (FBAR)
- Form 8938
- Foreign trust forms
Learners will also consider how missed filings can affect statutes of limitation, penalties, and financial statement considerations.
Hands-on learning to develop your skills
Practical examples illustrate how PFIC classification and excess distribution calculations can affect taxpayers. Reporting-focused content connects PFIC ownership with broader foreign asset and trust compliance obligations.
Note: This program includes content from the U.S. International Tax Certificate.
Who Will Benefit
- Tax practitioners advising U.S. persons with foreign investments
- CPAs and accounting professionals working with international tax compliance
- Professionals responsible for identifying PFIC issues and related reporting requirements
- Trust and estate professionals with clients holding foreign funds or foreign assets
Key Topics
- Passive foreign investment companies (PFICs)
- PFIC income and asset tests
- Excess distribution regime
- QEF election
- MTM election
- PFIC look-through rules
- Form 8621 reporting
- FBAR, Form 8938, and foreign trust reporting
Learning Outcomes
- Identify the structure of passive foreign investment companies (PFICs).
- Differentiate among PFIC regimes.
- Identify PFIC reporting requirements and foreign asset reporting requirements.
Group ordering for your team
2 to 5 registrants
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