PFICs Gone Wild!

29 Akron Tax Journal 29 (2014)

35 Pages Posted: 7 Sep 2013 Last revised: 26 May 2015

See all articles by Monica Gianni

Monica Gianni

California State University Northridge

Date Written: March 1, 2013


This article discusses the U.S. tax rules for passive foreign investment companies, or PFICs. The historical development leading up to the enactment of the PFIC rules in 1986 is examined. Unexpected tax consequences resulting from the PFIC rules are analyzed in detail. Recommendations to modify the rules so that they do have such onerous consequences follow, concluding that the PFIC rules cannot be sufficiently fixed and should be repealed.

Keywords: passive foreign investment company, PFIC, tax deferral, Subpart F

JEL Classification: K34

Suggested Citation

Gianni, Monica, PFICs Gone Wild! (March 1, 2013). 29 Akron Tax Journal 29 (2014), Available at SSRN: or

Monica Gianni (Contact Author)

California State University Northridge ( email )

David Nazarian College of Business and Economics
18111 Nordhoff
Northridge, CA 91330-8372
United States
8186772449 (Phone)

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