EXCEPTIONS TO PFIC REPORTING – Expat Tax Professionals, PFIC 101: What is a Passive Foreign Investment Company?, PFIC 101: What is a Passive Foreign Investment Company?, PFIC 101: What is a Passive Foreign Investment Company?, PFIC Test Exceptions • Certain Corporations During the Start-Up Year (i) Exception for start-up companies that engage in active business operation, with passive income in the first taxable year of operations (ii) Limited guidelines under the code and regulations (iii) Not reasonably tailored to provide relief in real-life cases.
return. This exception requires Form 8621 to be filed ( and PFIC tax consequences to apply) only for the portion of such taxable year that Form 1040NR does not apply. This exception generally mirrors an exception for the filing of Form 8938 (Statement of Specified Foreign Financial Assets) that was adopted in response to public comments (PwC, 1/8/2020 · Generally, a foreign company that would otherwise meet the PFIC criteria will not be treated as a PFIC for its first taxable year in which it earns gross income (the “startup exception”). In order to meet the startup exception, the following requirements must.
4/17/2019 · Start-Up Year Exception. A corporation that would otherwise meet the criteria for a PFIC will not be treated as such for the first taxable year in which such corporation earns gross income.
