952(a)(2) defines subpart F income to include foreign base company income, which includes foreign personal holding company income (FPHCI) under Sec.
What does FPHCI stand for?
FPHCI stands for Foreign Personal Holding Company Income
This definition appears somewhat frequently and is found in the following Acronym Finder categories:
- Business, finance, etc.
- Federal Public Housing Authority
- Ferguslie Park Housing Association (UK)
- Florida Public Health Association (Green Cove Springs, FL)
- First Person Hide and Seek (online gaming)
- Family Practice Health Centre
- First Philippine Holdings Corporation (Philippines; private holdings company; est. 1962)
- Fisher & Paykel Healthcare Corporation Limited (medical equipment; Australia)
- Florida Palliative Home Care
- Foreign Personal Holding Company
- Frontier Primary Health Care (Pakistan)
- Forest Practices Habitat Conservation Plan (Washington State Department of Natural Resources)
- Five Points Historic District Association (Huntsville, AL)
- Federation to Promote Horticulture for Disabled People
- Finsbury Park Homeless Families Project (UK)
- Forensic 3D/CAD (Computer Aided Design) supported Photogrammetry
- Free Party Hand Grabber
- Friends of Peralta Hacienda Historical Park (California)
- Florida Public Health Institute
- Female Pattern Hair Loss
- First Peoples House of Learning (Peterborough, Ontario, Canada)
Samples in periodicals archive:
172, where the IRS ruled that income earned by shareholder-employees of foreign corporations under personal services contracts was not foreign personal holding company income (under the former foreign personal holding company provisions) where the clients of the corporations did not have a contractual right to receive the specific personal services of the shareholder employees and where the services involved were not so unique as to preclude substitution.
1, 2009, TIPRA provides look-through treatment for payments between related controlled foreign corporations under the foreign personal holding company income rules.
The taxpayer took the position that such gain does not give rise to foreign personal holding company income (FPHCI) within the meaning of Sec.
This rule is designed to end the deferral of subpart F and undistributed foreign personal holding company income that currently arises when the taxable years of a U.
They provide that a controlled foreign corporation's (CFC'S) distributive share of partnership income is excluded from foreign personal holding company income under Sec.