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US taxpayers who hold shares in Passive Foreign Investment Companies (PFICs) under section 1293 of the Internal Revenue Code (IRC) might face intricacies and difficulties in devising an efficient Tax strategy. Particularly, the mark-to-market election is considerably a challenging subject to deal with. This blog will elaborate on the intricacies of Section 1293 as per the latest 20214 US tax laws and assess its impact on PFIC tax liabilities.
Foreign corporations that generate income from assets rather than active business operations are called PFICs. Their primary objective is to invest passively. The US tax code emphasised stern rules on PFIC investments to prevent deferral tax strategies.
The US tax code section 1293 gives an option to US shareholders of PFIC to elect for mark-to-market taxation. Under this election, it is to be assumed that PFIC stock is sold on the first day of each year just to identify its fair market value (FMV). Let’s have a breakdown of the election’s propositions and implications:
The mark-to-market offers both benefits and drawbacks, which are discussed below:
Benefits:
Drawbacks:
The following are the factors that need to be focused on with additional care in deciding a mark-to-market election:
Section 1293’s mark-to-market election proposed and suggested a composed and complex strategy for PFIC shareholders. It provides an option to have predictable benefits, but at the same time, it brings a risk of increased income taxation and cash flow challenges. Hence, it is advisable to carefully assess the investment objectives, PFIC’s performance, and personal capability before planning to adopt this election.
In addition, it is to be remembered that you must consider getting in touch with a tax consultancy like Dimovtax.com in case of technical complexities and navigating the intricacies of PFIC taxation.
Call us today at (833) 829-1120, email us at info@dimovtax.com, or fill out the form and we’ll get in touch immediately.
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