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We need to know whether the 2 distributions from the PFIC undergoing liquidation is subject to the rules of distribution or gain. It is possible for a corporation to make a series of liquidating distributions, each of which is treated as a payment in exchange for the shares. As long as the corporation is in a state of liquidation, each of the distributions during the state of liquidation is a liquidating distribution under section 331. Whether a corporation is in a state of liquidation is a question of fact. The PFIC sold all its investments, paid its major liabilities, then distributed most of the cash to its investors.When a shareholder receives a distribution in complete liquidation of a corporation, the distribution is treated as full payment in exchange for stock. This is a special treatment for liquidating distributions, so the transaction is treated as if the shareholder sold the shares in exchange for the liquidating distribution. Then, after paying small liabilities and formally dissolving, it paid the remaining cash to the investors. If you determine that a PFIC is liquidating, treat each liquidating distribution as payment in exchange for the shares.The process of liquidation also arises when customs, an authority or agency in a country responsible for collecting and safeguarding customs duties, determines the final computation or ascertainment of the duties or drawback accruing on an entry.
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We assume that the investor is a US person, and he has invested in a PFIC.
By default, proceeds from PFICs are subject to 2 sets of rules.
When a PFIC makes a distribution to a shareholder, the distribution is separated into excess distribution and non-excess distribution.
The non-excess distribution may comprise dividends, return of basis, and capital gains as normal.
In addition, the term "liquidation" is sometimes used when a company wants to divest itself of some of its assets.