It is getting to be time for t6 passive foreign investment companies. - Many of my fellow CPAs think that the government made these rules so complex to make it unaffordable to own a foreign investment fund. - It's really complex, but with complexity comes tax planning choices. - Let's go over who has to file the form, as well as some of the unique items. - I'm sure all of you know the basics of it. - Let's look at just a few tax planning opportunities. - Let's start off with what's new. - It's pretty hard to understand, but I have nicely put it down below who must file. - The U.S. person, directly or indirectly, has to file the form. - Indirect is used in a different way than it does with controlled foreign corporations, which is another challenge with international tax law. - The same word is used differently in different aspects of it, and you always have to look up the definition. - We're going to get to that definition in a moment. - The person who receives a distribution, or ignites gain on a direct or indirect disposition of the piece, has to file the form. - We'll get back to the words "receives" and "recognized" in a second. - Information with regards to a market-to-market election is making an election and is following the annual information for market-to-market election. - Those are the five cases where a U.S. person has to file the form. - Let's get to indirect shareholders. - An indirect shareholder is a 50% or more shareholder, so you don't have to own all of the company. - I can only imagine how this would cause complete chaos in trying to not pay tax on somebody else's profits. - This is a real great tax planning choice. - Ken and I own stock of a British Virgin Islands...