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Topic: PFIC / UK LTD Company  (Read 1121 times)

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PFIC / UK LTD Company
« on: February 14, 2021, 05:03:20 PM »
As a USC can I be a shareholder and or a director in a UK LTD Company that trades financial products (similar to ,but not a hedge fund , but would be pooled money that would trade foreign exchange, stocks, bonds etc).  The real question is does something like this create PFIC issues that would make such an endeavor extremely costly from both a reporting and tax perspective.  This would be a start-up and not an established company so just doing the initial research to see if it is even something I should consider.  My intitial investigation would seem to indicate its probably a very bad idea but want to make sure I am interpreting this correctly?


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Re: PFIC / UK LTD Company
« Reply #1 on: February 23, 2021, 08:27:00 PM »
As a USC can I be a shareholder and or a director in a UK LTD Company that trades financial products (similar to ,but not a hedge fund , but would be pooled money that would trade foreign exchange, stocks, bonds etc).  The real question is does something like this create PFIC issues that would make such an endeavor extremely costly from both a reporting and tax perspective.  This would be a start-up and not an established company so just doing the initial research to see if it is even something I should consider.  My intitial investigation would seem to indicate its probably a very bad idea but want to make sure I am interpreting this correctly?

As Far as i understand there should not be PFIC issues if it is a US CFC. there would be Subpart F and GILTI ramifications which can be solved.


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