This document discusses the tax implications for U.S. shareholders holding Subordinated Securities in a Passive Foreign Investment Company (PFIC) or a Controlled Foreign Corporation (CFC). It covers the treatment of net capital gains, distributions, and the sale or exchange of Subordinated Securities under U.S. federal income tax rules. The document also addresses the potential treatment of Subordinated Notes as debt and the associated tax regulations.
documents/EFTA01365599.pdf
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