Portage Biotech Inc. (PRTG)

[bbhuey]

In the 10 k it says that according to IRS rules they qualify as a PFIC because more than 50 percent of their income was passive.
In this case you can be taxed on past allocable earnings and future allocable earnings if one of the three elections are not made.
Looking at the 10k and past years Isee 2017 and 2018
as having a net profit in this case you would be tax on than and also for future years if it qualifies.
This can be a big exposure if the IRS wants to drop the hammer on the U.S shareholdets