Passive Foreign Investment Company Provisions
In the case of a U.S. person owning a small interest in a widely held “offshore” investment company not controlled by U.S. persons or a CFC, Congress enacted the passive foreign investment company (“PFIC”) provisions. The PFIC tax computations impact U.S. taxpayers who hold foreign mutual funds and who established many foreign financial accounts. These types of accounts earn investment income. Congress was concerned that owners of these foreign financial accounts were not properly disclosing the investment income generated from foreign mutual funds or foreign financial accounts and enacted the PFIC provisions of the Internal Revenue Code.