top of page

Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deemed Dividend Rules

 

Strafford Publications recently requested that I present on the topic of Foreign Personal Holding Company Income under Code Section 954(c). The presentation will be made predominantly to attorneys and CPAs, with clients holding foreign investment assets. The Presentation will cover the following: 

 

Description

  1. Subpart F Rules and Definitions

    1. U.S.Shareholder

    2. Controlled Foreign Corporation

    3. Deemed dividend earnings

  2. Section 954(c)(1) Foreign Personal Holding Company Income (FPHCI) Inclusions

    1. Portfolio Income (Interest, Dividends, Royalties, Annuities)

    2. Commodities transactons

    3. Foreign Currency gains

  3. Section 954(b) Exclusions

  4. Section 954(c) Exceptions from FPHCI

    1. Active rents and royalties

    2. Active financing

    3. Same country exception

    4. Look-through rule

  5. Subpart F Mechanics and Calculations

  6. The program will also cover: 

  • What passive activities qualify for exclusion from FPHCI calculations?

  • How do the look-through rules operate to recharacterize certain dividend payments?

  • What is the reporting treatment of the sale of FPHC ownership interests?

  • How do the attribution rules function in determining ownership of an FPHC interest?

 

More information at: https://www.straffordpub.com/products/foreign-personal-holding-company-income-reporting-mastering-subpart-f-inclusions-and-deemed-dividend-rules-2017-05-11

​

Presentation Materials are available - (click here). 

 

IRS CIRCULAR 230 NOTICE: ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY HARLOWE & FALK LLP TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.

bottom of page