Guidance Offered on Reporting by U.S. Shareholders in PFICs

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IRS Notice 2010-34 provides interim guidance on new reporting requirements for U.S. shareholders in passive foreign investment companies, with an effective date that one practitioner says will be welcome in the tax community. The new requirements were enacted by the Hiring Incentives to Restore Employment Act. The measure put into place new tax code Section 1298(f), which says these shareholders must file an annual report “containing such information as the Secretary may require.” IRS says it is developing further guidance on the reporting obligations. “We're certainly pleased that they took a generous view on the effective date,” New York State Bar Association Tax Section Chairman Peter Blessing tells BNA.