The Friday Edition
A biweekly newsletter for international tax professionals
What’s New This Week?
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PFICs Inside SIPPs and Form 8621
Hello, it’s Phil Hodgen. Welcome to the Friday Edition, your every-other-week massive international tax missive. New and Upcoming I get questions. One of the recurring questions is about PFICs inside foreign retirement plans — like U.K. SIPPs: Must the U.S. employee file Form 8621 for PFICs held inside the retirement plan? Yes. The High-Level Road Map Assuming you have a trust (Reg. §301.7701-4(a)), you have to figure out how it and its participants are subject to U.S. income tax. There are only two categories of trusts: When you have a grantor trust, IRC §671 says “make the owner pay the…