Foreign personal holding company income (FPHCI) is defined for U.S. controlled foreign corporation rules[1] and, with modifications, for U.S. foreign tax credit rules.[2] It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties, certain related party rents and royalties, same country income, and certain other items. For purposes of the foreign tax credit, an additional exception requires look-through of certain income received from a controlled foreign corporation.
^26 USC 954(c) and 26 CFR 1.954-2. This definition is also used in other sections of 26 USC, including the passive foreign investment company rules.
^26 USC 904(d). See the discussion of passive income on pages 10-11 of IRS Publication 514 Also, prior foreign personal holding provisions, 26 USC 551-558, repealed in 2004, provided a separate definition.
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