federal_register: 05-23630

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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
05-23630 Guidance on Passive Foreign Investment Company (PFIC) Purging Elections Rule This document contains temporary regulations 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). 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 these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. 2005-12-08 2005 12 https://www.federalregister.gov/documents/2005/12/08/05-23630/guidance-on-passive-foreign-investment-company-pfic-purging-elections https://www.govinfo.gov/content/pkg/FR-2005-12-08/pdf/05-23630.pdf Treasury Department; Internal Revenue Service 497,254 This document contains temporary regulations 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...  

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