Buying Foreign Real Estate via corporation - Will this be a PFIC?

[Owen Franks]

Hi all,

I’m a US Citizen but we are stationed in the UK. From a UK tax perspective it’s better (by far) to buy new rentals via a Limited Liability Company. But I’m concerned from a US tax perspective that owning a foreign corporation who’s income is entirely passive (ie rent) will be classed as a Passive Foreign Investment Company (a PFIC) and I believe the taxes for these are bad too! Are there any accountants on here with experience in this area?

Many thanks

Owen