IRS Proposes to Define Active Conduct of a Trade or Business Under PFIC Rules

Proposed regulations would clarify the circumstances under which investment income a foreign insurance company earned is derived in the active conduct of an insurance business for determining whether the income is passive income, and thus the extent to which the company's assets are treated as passive assets in determining whether the company is a passive foreign investment company.

QEF Elections Under PFIC Rules

In enacting the PFIC rules in 1986, Congress created a complex and punitive tax regime for certain passive foreign investments that continues to plague U.S. taxpayers and their tax advisers.

When Becoming a U.S. Resident, Beware of PFIC Rules

As the workforce becomes more mobile, many non-U.S. citizens who become U.S. residents for work reasons have to deal with not only cultural adjustments but also the unanticipated workings of the PFIC tax regime.

Passive Foreign Investment Companies

This item assesses various planning alternatives that may help U.S. taxpayers avoid the negative aspects of the PFIC regime, including qualifying electing funds, mark-to-market elections, and various planning strategy options.

Individuals’ Use of Offshore Holding Companies (Part II)

This article explores the tax consequences of using an offshore company to make more significant investments in foreign businesses, including situations in which the use of an offshore holding company may be consistent with bona fide U.S. federal income tax planning objectives.

Newsletter Articles


50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.


2019 tax software survey

This annual survey shows how CPAs rate the tax preparation software they used during last tax season and how it handled the recent tax law changes.