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)
Learning Objectives (NASBA)
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.
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*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.
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