Outgoing Investment
What is a foreign personal holding company?
The term means a foreign corporation, which meets Code tests as to the source of its gross income and its stock ownership. Such tests are similar to those applied to personal holding companies. In general, a foreign personal holding company is not subject to an additional tax, but each U.S. shareholder is required to include in his gross income his share of the undistributed foreign personal holding company income as if it had been distributed to him as a dividend.
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