Passive Foreign Investment Companies ("PFICS")
Leonard Tuber has considerable experience in the field of the tax treatment of PFICS, and lectures widely to tax professionals on the topic.
The Tax Reform Act of 1986 legislated into law a tax regime for PFICS. By its terms, the IRS requires that shareholders of PFICS (such as the ownership of shares or equity in a non-U.S. mutual fund) must calculate the associated US tax liability with regard to these interests, in a way fundamentally different than the way US tax liability is calculated with respect to other investment income.
Leonard can advise you as to the issues, reporting requirements, and taxation of PFICS.