@taxuser77 , not knowing which country you are talking about (-- so no treaty considerations ---), your investment entity may be classed as a Passive Foreign Investment Company --PFIC. This is generally covered by section 1297 and follow-on sections of the IRS code. There is specific reporting and taxing requirements based on percentage ownership . There may also be Mark-to-Market taxing requirements. I am providing here a link to the code section below. Please familiarize yourself with the requirements. Also please consider engaging a tax professional familiar with international taxation --- this is complex.
26 U.S. Code § 1297 - Passive foreign investment company | U.S. Code | US Law | LII / Legal Informat...
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