Bruce, a U.S. citizen, owns a 3% interest in a passive foreign investment company (PFIC) and during

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Bruce, a U.S. citizen, owns a 3% interest in a passive foreign investment company ("PFIC") and during calendar year 2022, Bruce receives a distribution of $100,000. Previous distributions received by Bruce were $70,000 in 2019, $80,000 in 2020, and $95,000 in 2021. With respect to the 2022 distribution, Bruce will be subject to the onerous PFIC taxation rules because he has received an excess distribution.

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Posted Date: Jun 21, 2024 09:03 AM

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Bruce, a U.S. citizen, owns a 3% interest in a passive foreign investment company (PFIC) and during

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