[13771]
July 26, 2001
TO: ACCOUNTING/TREASURERS COMMITTEE No. 23-01
INTERNATIONAL COMMITTEE No. 46-01
TAX COMMITTEE No. 20-01
RE: DATA COLLECTION FOR 2001 PFIC SURVEY UPDATE
Each year, the Institute collects information from members regarding foreign companies
that may be treated as passive foreign investment companies or “PFICs” for US tax purposes.
After the information is aggregated and the names of the firms providing the information are
deleted, the Institute distributes an updated PFIC survey. Attached is a copy of the latest PFIC
survey, dated October 24, 2000. As in prior years, the 2000 PFIC survey includes the following
two categories of foreign companies that one or more Institute members suspect should be
treated as PFICs:
Category One Companies: The survey lists in “category one” only those companies that
are identified in their offering documents, annual reports, or other company-generated,
publicly-available documents as being (or as likely being) PFICs. Copies of the materials
relied upon in making this determination for additions to the “category one” listing are
included in the survey results.
Category Two Companies: The survey lists in “category two” all other foreign
companies that one or more Institute members presently suspect should be treated as
PFICs. The listing also includes any available information regarding Sedol number(s)
for each company’s securities. Where at least one other member has informed the
Institute that it would not treat a “category two” company as a PFIC, the survey
identifies that company with a marking of “**”.1
1 The survey also provides an alphabetical listing of companies previously included in “category two” that Institute
members participating in the survey no longer suspect should be treated as PFICs.
2ACTION REQUESTED:
Please review the attached 2000 PFIC survey and make any deletions, additions or
corrections to the “category one” and “category two” PFIC listings that are required. With
respect to the addition of any “category one” company, please include a copy of any publicly-
available document identifying the company as a PFIC. Send your survey results to the
Institute’s Ezella Wynn electronically (to ewynn@ici.org), by facsimile (to 202/326-5841) or by
regular mail, no later than Friday, September 14, 2001.
Thank you in advance for your participation in this important survey. Please contact the
undersigned (dflores@ici.org or 202/371-5436) with any questions regarding the 2001 PFIC
survey update.
Deanna J. Flores
Associate Counsel
Attachment
Attachment (in .pdf format)