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International Tax: An Overview of PFICs


Cost Free
Presentation Length 1.5 hours

Recorded DateOctober 25, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelIntermediate
Course Description

This course will detail the primary rules associated with passive foreign investment companies (PFICs). Included within the program will be guidance on determining whether a foreign interest qualifies as a PFIC, explicitly focusing on foreign entities’ classification and determinations regarding passive income levels (even where books and records are unavailable). The program will also review the specific default tax rules applicable to PFICs and where/how they apply. Additionally, the webinar will also outline alternative elections available for taxing PFIC interests and eligibility requirements.

Learning Objectives:

  • Identify when a foreign interest triggers the passive foreign investment company rules, with a specific focus on qualifying income/assets and foreign corporate status

  • Define the default rules regarding PFIC taxation, including appliable interest charges and gain reclassification

  • Identify elective alternatives to the default rules for PFIC treatment and requirements to be eligible for elective alterations

Not logged

Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.

Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.


About Our Presenter

Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.