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Passive foreign investment companies (PFICs) must meet either an asset test or an income test. See Explanation: §, Passive Foreign Investment Company. Passive Foreign Investment Company (PFIC) · Treated as if it realized any gain and excess distributions ratably over its holding period for the shares. · Taxed at. Passive Foreign Investment Company. The Company shall conduct its business, and shall cause its Subsidiaries to conduct their respective businesses.

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the average percentage of assets (as determined in accordance with subsection (e)) held by such corporation during the taxable year which produce passive. PFICs are simply “pooled investments” registered outside of the United States encompassing mutual funds, non-US pension plans, hedge funds, and insurance. A passive foreign investment company (PFIC) is defined as a non-U.S. corporation which has at least 75% of its gross income considered passive income, or at.

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A PFIC is a type of “foreign passive investment.” When a U.S. shareholder invests into a foreign company, and meets either the income or asset test, the tax. The literal definition of a Passive Foreign Investment Company is a foreign corporation of which at least 75 per cent of the income earned is “passive” i.e. PART VI - TREATMENT OF CERTAIN PASSIVE FOREIGN INVESTMENT COMPANIES Subpart D - General Provisions Sec. - Passive foreign investment company.