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The Passive Foreign Investment Company (PFIC) provisions attempt to limit or eliminate the tax deferral benefits afforded to U.S. shareholders of foreign corporations where the
The Passive Foreign Investment Company (PFIC) provisions attempt to limit or eliminate the tax deferral benefits afforded to U.S. shareholders of foreign corporations where the Controlled Foreign Corporation (CFC) regime does not accomplish this anti-deferral goal. In the context of the PFIC regime, briefly describe the main difference between "pedigreed qualified funds," "un-pedigreed qualified funds," and "non-qualified funds."
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