Understanding the basics of owning stock in a foreign company: CFC vs PFIC

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Description

Understanding the basics of owning stock in a foreign company: CFC vs PFIC
IRS Program #: X9QQU-T-01084-23-O
CTEC #: 6257-CE-0250
CE: 1 IRS & 1 CTEC credit
Speaker: Rita Ryan, JD, LLM

U.S. individuals with investments in foreign companies face multiple tax complexities. The U.S. has enacted legislation that prevents the deferral of profits earned through a foreign company. This anti-deferral rules cover two different types of companies: Controlled Foreign Corporation (CFC) or Passive Foreign Investment Company (PFIC). This session will discuss the basics of the anti-deferral regimes applicable to both CFC and PFICs, its tax implications and some of the basics of the applicable reporting rules.

Learning Objectives:

Determine the tax implications applicable to a U.S. person owning foreign companies.
Identify a CFC.
Identify a PFIC.
Establish the precise tax implications of a CFC and a PFIC.
Identify the basic reporting rules applicable to a CFC and PFICs.

Contributors

Rita Ryan, J.D, LLM

Rita leads Wolf’s International Tax Services Practice, where she focuses on tax planning and compliance for international holdings. Rita has extensive experience advising clients on the tax aspects of cross-border business activities, structuring international investments, and the United States compliance obligations relating to these activities and investments for both entities and individuals. Rita also works with other tax professionals as a trusted advisor to identify necessary reporting, advise on filings, or review work papers and prepared forms to ensure accuracy in this evolving international compliance landscape.

Prior to joining Wolf, Rita was in private practice as an Associate Attorney at the law firm of Vacovec, Mayotte & Singer, LLP where she focused in the areas of international and domestic taxation, estate planning, and tax controversy.

Rita is an Adjunct Professor at the Graduate Tax Program at Boston University School of Law where she co-founded and co-teaches “Foreign Information Reporting and Withholding.” She also teaches various other international tax topics for Strafford Publications, Tax Practice Pros, and Wolters Kluwer.

Involvement
- International Fiscal Association (IFA)
- Women of IFA Network (WIN)
- Massachusetts Bar Association
- Allinial Global, Inc.
Education
- Bachelor of Arts in History from Marist College
- Juris Doctor in Law from the Western New England University School of Law
- Master of Laws in Taxation from the Boston University School of Law
- Massachusetts Bar Association Leadership Academy Fellow

Thank you

Description

Contributors

Rita Ryan, J.D, LLM