federal_register: 05-23628
Data license: Public Domain (U.S. Government data) · Data source: Federal Register API & Regulations.gov API
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| document_number | title | type | abstract | publication_date | pub_year | pub_month | html_url | pdf_url | agency_names | agency_ids | excerpts | regulation_id_numbers |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 05-23628 | Guidance on Passive Foreign Investment Company (PFIC) Purging Elections | Proposed Rule | In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide certain elections for taxpayers, who in limited circumstances, continue to be subject to the 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(e). The regulations are necessary to provide guidance about purging the PFIC taint for such foreign corporations. The regulations will affect U.S. persons that hold stock in a PFIC. The text of those temporary regulations also serves as the text of these proposed regulations. This document also provides notice of a public hearing on these proposed regulations. | 2005-12-08 | 2005 | 12 | https://www.federalregister.gov/documents/2005/12/08/05-23628/guidance-on-passive-foreign-investment-company-pfic-purging-elections | https://www.govinfo.gov/content/pkg/FR-2005-12-08/pdf/05-23628.pdf | Treasury Department; Internal Revenue Service | 497,254 | In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that provide certain elections for taxpayers, who in limited circumstances, continue to be subject to the excess distribution regime of... |