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PFIC's Through a Historical Lens


DooDiligence
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GRVY for a long time.

Pershing Square.

 

For search, one of the tax explanation links used to have a list, but possibly old and definitely incomplete.

 

May I ask what is a goal of this? I don't think you gonna get any non-anecdotal outcome from looking at PFICs. Especially since they come in at least three different flavors: investment funds (Pershing), tons of cash net-nets (GRVY) and resource/gold holders (Sprott something?).

 

The investment funds are most hairy for me to determine if they are PFIC or not. E.g. Investor Holdings. Or Exor. Or Bollore. I think it depends if their wholly owned subs are consolidated into and more than ??% owned, but IANATaxAccountant and all that. I guess cash rich net nets can be hairy too if they dance close to the limit.

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is the hypothesis that there's a "PFIC premium" ( or in other words a PFIC discount in pricing,ie you get paid more to own PFIC's) because of their onerous filing requirements?

 

I think my largest holding, TFG NA,  would trade a bit higher if it wasn't a PFIC, but there's no way to prove how much of the discount is related to fees / management / illiquidity or PFIC status as all of those apply

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Thanks for the rabbit holes guys (no really, thanks!)

 

No real hypothesis yet, just not real aware of how these things work through time.

 

My thought was that they'll maybe increase ownership of a biz (I'm anchored to the Bangalore airport situation with FFXDF) & eventually own all of it with management in place.

 

What happens next? The shares are no longer traded so the previous NAV is no longer a determinant & the IV of the biz is?

 

Do they just continue being a PFIC & take their share of the profits (I guess they could sell parts of the wholly owned biz too.)

 

Maybe the structure is less important than I was thinking as long as the fractional ownership stakes perform in the market & any wholly owned business continues kicking up (and I'm assuming owning in a 401K gets rid of the tax burden?)

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I'm not entirely sure why it matters?  In 'home' markets the market can value these properly.  It's only the weird tax system in the US for investors who decide to buy a foreign stock.

 

I know Fidelity allows you to buy ETF's on the Japanese exchanges.  These are all PFIC's, as expected.  But it doesn't matter.  Japanese investors, in Japan are buying them in the normal course of business.

 

It'd be like asking if some obscure tax in some other country has an effect on US stocks.  It's not likely.

 

The ONLY case where I can see that this matters is for cash rich American companies that listed on the AIM 2006 and 2007 during that boom.

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What Nate said.

 

The history of this rule is to reduce competition for US fund companies.  Basically PFICs are funds (of course, all foreign funds are PFICs, but not all (but most) PFICs are funds).

 

I think the OP probably cares about:

- companies that turn into PFICs

- companies that are non-traditional PFICs

- (1) or (2) + companies w/ lots of US based investors

 

Otherwise, it's like asking how stocks perform with tickers starting with "G".  It's kind of not-relevant.

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What Nate said.

 

The history of this rule is to reduce competition for US fund companies.  Basically PFICs are funds (of course, all foreign funds are PFICs, but not all (but most) PFICs are funds).

 

I think the OP probably cares about:

- companies that turn into PFICs

- companies that are non-traditional PFICs

- (1) or (2) + companies w/ lots of US based investors

 

Otherwise, it's like asking how stocks perform with tickers starting with "G".  It's kind of not-relevant.

 

Right & right.

 

Thanks again.

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  • 4 years later...

Posted this under Exor thread as well. Thanks.

 

 

Will the forming of Stellantis change Exor's PFIC status? My understanding is that Exor can count holdings where it has over 25% ownership as active businesses  in the PFIC assets tests(at least 50% active businesses assets)  or income tests(at least 75% from active businesses income). Prior to the Stellantis deal, FCA can be counted towards active businesses since Exor's ownership is >25%. Post Stellantis deal, Exor's ownership of Stellantis is < 25%. If we exclude Stellantis assets and earnings in the calculation, the asset and income test might not meet, or getting very close to the 50% and 75% thresholds.  Is my understanding correct? Appreciate any feedback US investors might have on this issue. 

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