PFIC Happens: A §1291 Deep Dive
PFICs are one of the most complex areas in international tax—and when the default rules under IRC §1291 apply, the real challenge is not identifying the issue, but performing the calculation correctly. The excess distribution regime requires practitioners to reconstruct holding periods, allocate income across multiple years, and apply interest charges that can significantly increase the tax liability.
This program is a hands-on, practical deep dive into §1291. Participants will work through the mechanics of the excess distribution rules, including allocation across the holding period and the computation of tax and interest. The program also addresses key elections, including qualified electing fund (QEF) and mark-to-market elections, and the consequences of failing to make timely elections.
Special attention is given to real-world practitioner challenges, including incomplete information, prior-year errors, and determining the best path forward when a client is already subject to the §1291 regime. The session emphasizes step-by-step application and practitioner decision-making, translating complex rules into a structured approach that can be applied in practice.
This is not an introductory overview—this is a working session for practitioners who need to calculate, analyze, and resolve PFIC issues under §1291.
NASBA Intermediate level program
PREREQUESITE 2-3 experience working with PFIC calculations, or attendance at our basic PFIC program (available online)
Upon completion of this program, participants will be able to:
-Identify when a foreign investment is classified as a PFIC and determine when the §1291 regime applies.
-Compute tax under the excess distribution rules, including allocation of income across the holding period.
-Calculate the applicable interest charge associated with §1291 inclusions.
-Evaluate the impact of QEF and mark-to-market elections and determine when such elections are beneficial.
-Analyze common PFIC compliance issues and apply practical strategies for reporting on Form 8621.
Only available for TPP unlimited CE subscribers.
"Our best deal is always to become a monthly subscriber"
*Self-Study recording not available for NASBA CPE credit.
IRS Program #: 7Q3WU-T-00891-26
CTEC Course #: 6248-CE-00237
Rita Ryan
,
Esq., LLM
Rita Ryan is the Founder of RRITS and a seasoned Tax Attorney with more than 18 years of experience advising clients on cross-border personal/business taxation, international investment structuring, multi-jurisdictional estate planning, and U.S. tax compliance obligations arising from global activities and holdings. She is widely regarded for her ability to navigate complex international tax regimes and translate evolving regulatory requirements into practical, strategic guidance.
In addition to her client-facing work, Rita serves as a trusted advisor to fellow tax professionals, providing specialized support in identifying international reporting obligations, advising on complex filings, and reviewing workpapers and forms to ensure technical accuracy in an increasingly dynamic international compliance environment.
Prior to founding RRITS, Rita served as Chief Financial Officer and Head of Private Client Services at M+, where she focused on integrated tax, business, and wealth preservation planning for high-net-worth business owners and their families. Earlier in her career, she founded and led Wolf & Co.’s International Tax Services Practice, advising both individuals and entities on the tax planning and compliance aspects of international ownership structures. Rita began her legal career in private practice as an Associate Attorney at Vacovec, Mayotte & Singer, LLP, concentrating on international and domestic taxation, estate planning, and tax controversy matters.
Rita is also an Adjunct Professor in the Graduate Tax Program at Boston University School of Law, where she co-founded and co-teaches the course Foreign Information Reporting and Withholding. In addition, she regularly teaches advanced international tax topics for Tax Practice Pros, LumiQ, and the National Association of Enrolled Agents, contributing to the education of practitioners nationwide.
Recommended Webinars
2024 Tax Controversy Seminar Series
Varies
This on-demand webinar series covers criminal tax, IRS collections, international reporting, tax controversies, AI in tax practice, and entertainment industry taxation, equipping professionals with practical strategies for compliance, dispute resolution, and risk management
FBAR Rescue & 8938 Reasons to File
2 IRS CE/2 CTEC/2 NASBA CPE*
Taxpayers with foreign financial assets may be required to file both the Foreign Bank Account Report (FBAR) and Form 8938 (Statement of Specified Foreign Financial Assets)—but understanding when and how to file can be complex. This webinar guides tax professionals through the key differences, filing thresholds, penalties, and reporting obligations for each form. Learn how to determine filing requirements, avoid common compliance pitfalls, and effectively advise clients with international financial interests. Ensure your clients stay compliant and mitigate risks with a clear understanding of these critical reporting requirements. Only available for TPP unlimited CE subscribers.
International Tax Controversies: Challenges & Strategies - 2025
4 Free NY & NJ CLE, CPE and 4 IRS CE/4 NASBA CPE Credits
This in-depth program provides comprehensive coverage of the tax implications for U.S. taxpayers with foreign income and assets. Participants will explore the complexities of reporting foreign income, compliance requirements for foreign asset disclosure, and strategies for minimizing tax liabilities under international tax treaties. The program addresses key areas such as the Foreign Account Tax Compliance Act (FATCA), the Foreign Bank and Financial Accounts (FBAR) reporting, and the taxation of foreign trusts. It also includes a discussion on the tax treatment of foreign earned income and the benefits of the Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credit (FTC). The session features practical examples and case studies to help attendees navigate the intricacies of international taxation effectively and ensure compliance with both U.S. and foreign tax laws.
Trust Me Webinar Series
20 IRS/NASBA CPE credits
Tax Practice Pro’s 2024 Trusts & Estates Webinar Series offers on-demand, IRS/NASBA CE-approved training for tax professionals, covering estate and trust taxation, gift and portability planning, special needs strategies, Form 1041 and 706 line-by-line guidance, and practical trust case studies to enhance client outcomes.
Trust Me Webinar SeriesEntities & Partnerships Series
25 IRS/NASBA CPE Credits Available
TPP’s Partnership & S Corporation Tax Series provides 25+ IRS/NASBA CPE credits with in-depth training on Form 1065 and 1120-S preparation, partnership basis and capital accounts, Section 754 and 751 issues, BBA compliance, S corporation reasonable compensation, liquidations, reorganizations, and advanced pass-through taxation strategies.
Entities & Partnerships SeriesRepresentation Like it's 2019—Post Pandemic Series
Varies
In this comprehensive series, we will delve into the intricacies of IRS Representation procedures, providing actionable insights and strategies to help you confidently represent your clients. Whether you're a seasoned practitioner or just starting out, this series will provide you with the knowledge and tools needed to handle IRS collection cases, exams and appeals with proficiency and professionalism.
Representation Like it's 2019—Post Pandemic Series2024 Tax Controversy Seminar Series
Varies
This on-demand webinar series covers criminal tax, IRS collections, international reporting, tax controversies, AI in tax practice, and entertainment industry taxation, equipping professionals with practical strategies for compliance, dispute resolution, and risk management
2024 Tax Controversy Seminar Series2023 Tax Controversy Seminar Series
Varies
This on-demand and live tax law series offers practical guidance on substantiating deductions, proving entitlement to losses, domestic and international tax controversies, U.S. Tax Court trial procedures, the Federal Rules of Evidence, ethics in tax practice, and the role of expert witnesses, providing essential insights for tax professionals.
2023 Tax Controversy Seminar SeriesTaxation of Investment Income Mini-Series
Varies
This 8 IRS CE credit Investment Taxation Miniseries equips tax professionals with advanced guidance on reporting stock and mutual fund sales, dividends, DRIPs, employee stock options, investment interest deductions, trader vs. investor status, basis calculations, bond taxation (including OID and tax-exempt bonds), capital gain netting, and cryptocurrency transactions.
Taxation of Investment Income Mini-SeriesTax Audit and Representation Series
32 IRS/32 NASBA CPE Credits Available
Tax Practice Pro’s IRS Representation & Controversy Webinar Series provides tax professionals with on-demand, IRS/NASBA CE-approved training on Forms 2848 and 8821, penalty abatement, audits, collections, transcript analysis, Tax Court procedures, ERC exams, passport revocation issues, FOIA requests, and practical IRS defense strategies.
Tax Audit and Representation Series
Hmm...nothing here yet.
