Page 20 - International Taxation IRS Training Guides

Outbound Anti-Deferral Rules

 Main Anti-Deferral Regimes:

• Subpart F income:

− Passive income (dividends, interest, rent, royalties and
annuities)

− Related party
sales and services income

− Many exceptions and opportunities for deferral planning

in U.S. Property
• Investments
that bring earnings back to U.S. without a
− Targeted at acts
“dividend”.
E.g., loans to U.S. related party.
• Passive Foreign Investment Company (“PFIC”)

− >75% of gross income passive or > 50% assets produce passive
or no income

 Consequence: Current U.S. tax, potentially reduced by
FTCs.

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