Page 219 - International Taxation IRS Training Guides

Passive Foreign
Investment Company

(PFIC)
Insurance Exception

 Foreign corporation that
is not a CFC is a PFIC if (1)

75% or more of i t s
gross income is passive income, or
the
(2) the average percentage of assets held by

which produce
corporation during the taxable year

passive income (or which are held for the production of
is at least 50%
passive income)

there was an exception from passive
 Before TCJA,
investment income derived from the active
income for

conduct of
an insurance business

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