- Federal Taxes
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Tax Controversy Services
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This section addresses questions frequently asked by our clients. Please contact our offices for more detailed information regarding these subjects or with any other tax questions you may have.
This section contains timely information, relevant articles and publications that may pertain to your particular interests.
This section will allow you to download various forms from our website.
Services
International Tax
Passive Foreign Investment Companies
The IRS defines a Passive Foreign Investment Company (PFIC) as a foreign corporation, which meets either an asset or income test. Passive income is usually income such as dividends, interest and rents and royalties.
- Under the asset test the foreign corporation will be considered a PFIC if 50% or more of the average value of the foreign corporation’s assets are made up of assets that produce passive come.
- The income test is met if 75% or more of the foreign corporation’s gross income is passive income.
U.S. persons that are a direct or indirect shareholder of a PFIC may have to file Form 8621. Form 8621 must be attached to the shareholder’s tax return and filed with the IRS by the due date, including extensions or pay a penalty on any deferred income from the foreign investment company.
The Esquire Group team of international advisors is prepared to assist you in determining your obligation to file and to complete any necessary documents.
