Why pfic rules

15 dic. The general rule is that a foreign corporation is a PFIC if either 75% or more of its income is considered passive income (the “Income Test”) or. PFIC rules were modified by the Tax Cuts and Jobs Act (TCJA). The changes involved an exception relating to the insurance industry. Under U.S. tax law, Canadian mutual fund trusts and mutual fund corporations are generally considered PFICs, which are subject to strict rules designed to limit.