Reading through 8621 instructions and ran into the following. What is the difference between these distribution and disposition when used as follows.
1.
Receives certain direct or indirect
distributions from a PFIC,
2.
Recognizes gain on a direct or
indirect disposition of PFIC stock
thank you.
Difference between distribution and disposition, 8621
Moderator: Mark T Serbinski CA CPA
These are rules for shareholders owning shares in passive foreign investment company holdings. As a shareholder you may own these shares directly in your name or through say a holding company that you also own ( this is indirect since its owned by an other entity that you own) as long as there is a 10% ownership either directky or indirectly you are required to file the 8621. Ownership through a trust will also be considered an indirect holding if the trust is discretionary.
JG
I think he is asking NOT about direct/indirect, but rather disposition and distribution.
Distribution is "dividends" that can either be cap gains, dividends, or interst, distributed periodically to the fund (internal gains if you will),
A disposition would be an outright sale of the investment.
Distribution is "dividends" that can either be cap gains, dividends, or interst, distributed periodically to the fund (internal gains if you will),
A disposition would be an outright sale of the investment.
nelsona non grata. Non pro. Please Search previous posts, no situation is unique as you might think. Happy Browsing