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Foreign personal holding company income ( FPHCI) is defined for U.S. controlled foreign corporation rules [1] and, with modifications, for U.S. foreign tax credit rules. [2] It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties ...
For purposes of income tax in the United States, U.S. persons owning shares of a passive foreign investment company ( PFIC) may choose between (i) current taxation on the income of the PFIC or (ii) deferral of such income subject to a deemed tax and interest regime. [1] The provision was enacted as part of the Tax Reform Act of 1986 as a way of ...
Organization. Trade. Business and economics portal. v. t. e. A holding company is a company whose primary business is holding a controlling interest in the securities of other companies. [1] A holding company usually does not produce goods or services itself. Its purpose is to own stock of other companies to form a corporate group .
20%***. * This rate was reduced one-half percentage point for 2001 and one-half percentage point for 2002 and beyond. ** There was a two percentage point reduction for capital gains from certain assets held for more than five years, resulting in 8% and 18% rates. *** The gain may also be subject to the 3.8% Medicare tax.
The qualified dividend tax rate for tax year 2023 — filing in 2024 — is either 0%, 15% or 20%. These rates are influenced by your tax bracket, which is determined by your filing status and ...
Foreign personal holding company income (FPHCI), including dividends, interest, rents, royalties, and gains from alienation of property that produces or could produce such income. Exceptions apply for dividends and interest from related persons organized in the same country as the CFC, active rents and royalties, rents and royalties from ...
Bank holding companies are corporations that own controlling interests in one or more banks and manage their operations. Advantages of a bank holding company can include reduced overall risk and ...
A personal service corporation is a company which, as the name suggests, provides personal services. These services span a wide variety of endeavors in many fields, and are specified for tax purposes in the United States by the Internal Revenue Service (IRS). This type of corporation has some tax advantages, such as various tax-free fringe ...