Tag Archives: Chief Counsel Advice (CCA) 201003013

How the logic of the quantifiers: "All", "Some", and "Not All" apply to Canadian mutual funds


What is a PFIC?
The acronym “PFIC” stands for “Passive Foreign Investment Corporation”. For your reading pleasure, I refer you to:
S. 1297 of the Internal Revenue Code which defines what a PFIC is; and
S. 1291 of the Internal Revenue Code which describes the “default taxation” of a PFIC.
Assuming that all Canadian mutual funds are PFICs, the results are horrific. I have written about this problem in two separate submissions to the U.S  Senate Finance Committee.
Continue reading