Required when there is distribution of income from a passive foreign investment company (PFICs) in which a U.S. person is a shareholder or a disposition of the shares of a PFIC by gift, death and most types of otherwise tax free exchanges or redemptions.
This form must be filed to compute the tax due on any “excess distributions” from or dispositions of a PFIC. Generally, an “excess distribution” is a distribution (after the first year) that exceeds 125% of the average distribution in the previous three years. All dispositions appear to be treated as excess distributions and are treated the same as distributions in excess of 125% of the average distributions
- Analyzing global organization structure inbound and outbound tax transactions issues.
- Global mobility and across boarder tax consulting including tax equalization and retirement plans.
- Expatriation /exit tax returns including form 1040NR dual status citizen and form 8854. This is required when a US person abandon his/her green card or renouncing US citizenship.