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For purposes of income tax in the United States, U.S. persons owning shares of a passive foreign investment company (PFIC) may choose between (i) current taxation on the income of the PFIC or (ii) deferral of such income subject to a deemed tax and interest regime.〔(26 USC 1291-1298 ).〕 The provision was enacted as part of the Tax Reform Act of 1986 as a way of placing owners of offshore investment funds on a similar footing to owners of U.S. investment funds ((regulated investment companies )).〔See the Conference Committee Report pages II-640, et seq., on Section 1235 of the Tax Reform Act of 1986.〕 The original provisions applied for all foreign corporations meeting either an income or an asset test. However, 1997 amendments〔(Section 1121 of PL 105-34 ).〕 limited the application in the case of U.S. Shareholders of controlled foreign corporations. ==Definition== Any foreign (i.e., non-U.S.) corporation meeting either the income test or the asset test is a PFIC with respect to each shareholder when the test is met.〔(26 USC 1297 ).〕 PFIC status applies separately for each U.S. person owning shares, and also separately with respect to shares acquired at different times. PFIC status does not, itself, have any impact on the foreign corporation or foreign shareholders. The ''income test'' is met if 75% or more of the foreign corporation's gross income is passive income, defined as foreign personal holding company income with modifications. The ''asset test'' is met if 50% or more of the foreign corporation's average assets (as defined in the IR Code) produce, or could produce passive income, or are assets (such as cash and bare land) that produce no income. The test is applied based on the foreign corporation's adjusted basis, for U.S. tax purposes, of the assets, or at the election of the particular shareholder, fair market values of the assets. Look-thru of 25% subsidiaries: Interests in 25% or more owned foreign corporations are treated similarly to partnership interests (i.e., looked through) for the income test and the asset test. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Passive foreign investment company」の詳細全文を読む スポンサード リンク
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