Guidance on Passive Foreign Investment Company (PFIC) Purging Elections
other · IRS · Rule · Published 2005-12-08 · Effective 2005-12-08 · 70 FR 72914
Document
Document number
05-23629
Federal Register citation
70 FR 72914
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2005-12-08
Effective date
2005-12-08
Treasury docket
TD 9231
Abstract
This document contains final regulations that provide specific elections that give relief to certain United States persons that continue to be subject to the PFIC excess distribution regime of section 1291 even though the foreign corporation in which they hold stock no longer satisfies the definition of a PFIC under section 1297(a). The final regulations affect U.S. persons owning stock in a PFIC.