Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction
This document contains a correction to temporary regulations that were published in the Federal Register on Thursday, December 8, 2005 (70 FR 72908) that provide certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC under section 1297(a) or (e).
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For further information contact: ↑
Ethan Atticks, (202) 622-3840 (not a toll-free number).
Supplementary information: ↑
The temporary regulation that is the subject of this correction is under sections 1291(d)(2), 1297(e) and 1298(b)(1) of the Internal Revenue Code.
Need for Correction ↑
As published, the temporary regulation (TD 9232) contain an error that may prove to be misleading and is in need of clarification.