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I invested in a PFIC. The PFIC decided to liquidate. Csh sold all distrbiutions investments, paid its major liabilities, then paid most of disttibutions cash proceeds to its investors. Then, after paying miscellaneous, small debts and winding up distrihutions business, it distributed the remainder of its cash to the investors. I lost money on the investment. By default, proceeds from PFICs are subject to lroceeds sets of rules.
When a PFIC makes a distribution to a distributiosn, the distribution is separated into excess distribution and non-excess distribution. The non-excess distribution may comprise dividends, return Liquidatihg basis, and capital gains as normal. The excess distributipns is subject to tax, even if it is entirely return of basis. Exactly how the tax is calculated is beyond the scope of this post, but an important item to note Liquidating distributions cash proceeds that if a distribution is taxed as an excess distribution, then even return of basis, which fistributions normally tax-exempt, is taxable.
When a shareholder realizes a gain from disposing of a PFIC distributios, the cas gain is taxed as excess distribution. But the way dstributions calculate gain follows the ristributions rules: Gain equals amount realized minus Luquidating basis. Thus, if a distribution is taxed as a sale of a PFIC, then the return of basis is not taxable. We need to know whether the 2 distributions from the PFIC undergoing Liquidtaing is subject to the rules of distribution or gain.
Liquidating distributions are normally treated as proceeds from sale When a shareholder receives a distribution in complete liquidation of a corporation, the distribution is treated as full payment in exchange for stock. This is a special treatment for liquidating distributions, so the transaction is treated as if the shareholder sold the shares in exchange for the liquidating distribution.
Normal rules for calculating gain or loss apply. Thus, a portion of the amount realized equal to the adjusted basis the return of basis is not gain and is not included in income. It is possible for a corporation to make a series of liquidating distributions, each of which is treated as a payment in exchange for the shares. Olmsted vs Commissioner, TC Memo As long as the corporation is in a state of liquidation, each of the distributions during the state of liquidation is a liquidating distribution under section Olmsted, TC Memo Whether a corporation is in a state of liquidation is a question of fact.
In our case, the facts are simple. The PFIC sold all its investments, paid its major liabilities, then distributed most of the cash to its investors. Then, after paying small liabilities and formally dissolving, it paid the remaining cash to the investors. This is a classic case of liquidation, and there is little question that both the initial large cash distribution and the following remainder cash distribution would be liquidating distributions had the corporation been a normal corporation rather than a PFIC.
The question is whether the PFIC rules override the liquidating distribution rules. You get liquidating distribution treatment The IRS has not adopted any regulations on this matter, but the proposed regulations are fairly clear: Liquidating distributions are treated dispositions of the PFIC shares, not distributions in respect of shares; and a series of liquidating distributions is treated as a series of dispositions on each liquidating distribution date.
If you determine that a PFIC is liquidating, treat each liquidating distribution as payment in exchange for the shares. When the payment results in a gain according to the normal methods of calculating gain, you recognize gain and calculate tax on the gain under PFIC rules on the date of distribution. In our scenario, it is clear that the PFIC is liquidating. Thus, the first cash payment is treated as payment in exchange for the PFIC shares. Because our investor lost money on the investment, I assume the payment is less than his adjusted basis in the PFIC shares.
Thus, there is no gain. Likewise, the second cash payment is treated as payment in exchange for the PFIC shares. Because our investor lost money on the investment, I assume the payment is still less than his adjusted basis in the PFIC shares—after the reduction from the first payment. Fortunately, our investor does not need to pay tax on the losses from the PFIC liquidation.
Most likely, the investor has a capital loss.