The document discusses the tax implications for U.S. holders of Preferred Shares in a non-U.S. corporation, specifically addressing the classification of the corporation as a Controlled Foreign Corporation (CFC) or a Passive Foreign Investment Company (PFIC). It outlines the tax consequences for U.S. shareholders under both classifications and the potential election to treat the corporation as a Qualified Electing Fund (QEF).
doj/DataSet10/EFTA01386899.pdf
{"document_date":"February 2018","document_type":"financial","key_organizations":["Alpha Group Capital LLC"]}