July 2017 JD Supra

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting.  PFIC computations are challenging for a Taxpayer in an amnesty program such as the OVDP.  There is a challenge due to the lack of historical information on the cost basis and holding period of the PFIC.  PFIC Computations and the verification process are often reasons why an OVDP closing agreement may be delayed.