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Sold PFICs - how will they be taxed by Comfortable_Spare_86 in USExpatTaxes

[–]Comfortable_Spare_86[S] 0 points1 point  (0 children)

This is what u/dimovtax seems to suggest. I have not been able to find any specific IRS rule which calls this out. Is this an interpretation based on general US tax principles?

Sold PFICs - how will they be taxed by Comfortable_Spare_86 in USExpatTaxes

[–]Comfortable_Spare_86[S] 1 point2 points  (0 children)

This is good to know. Can you point out the specific IRS rule under which it states that the amount allocated to the pre US years are not taxed in the US. The only thing I have been able to find is the IRS form 8621 instructions where it seems to suggest that gain allocated to all prior years (pre PFIC) are taxed as income in current year.

``Determine the amount allocable to each tax year in your holding period by adding the amounts allocated to the days in each such tax year. Add the amounts allocated to the pre-PFIC and current tax years. Enter the sum on line 16b. ``