On December 30, 2013, the IRS released temporary regulations related to annual filing requirements for Passive Foreign Investment Company (PFIC) shareholders and provided guidance on determining the ownership of a PFIC. The regulations also provided an exclusion for shareholders that constructively own interests in certain foreign corporations. Read more in a February 2022 article from PWC.
U.S. Estate and Gift taxes are considered "transfer" taxes and not "income" taxes and the tax is asserted against the person making the transfer. The U.S. Estate and Gift taxes apply differently to U.S. persons and non-U.S. persons, and some of the rules depend on if the non-U.S. person is considered a resident (which are not the same as traditional...