Treatment of Shareholders of Certain Passive Foreign Investment Companies
other · IRS · Rule · Published 1996-12-27 · Effective 1996-12-27 · 61 FR 68149
Document
Document number
96-32246
Federal Register citation
61 FR 68149
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
other
Sub-agency
IRS
Publication date
1996-12-27
Effective date
1996-12-27
Treasury docket
TD 8701
Abstract
This document contains final regulations that provide rules for making the deemed sale and deemed dividend elections under section 1291(d)(2). These regulations reflect changes to the law made by the Tax Reform Act of 1986 and the Technical and Miscellaneous Revenue Act of 1988, and apply to a shareholder of a passive foreign investment company (PFIC) that elects under section 1295 to treat the PFIC as a qualified electing fund (QEF) for a taxable year after the first taxable year during the shareholder's holding period that the foreign corporation was a PFIC.