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federal_register: E7-18988

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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
E7-18988 Guidance on Passive Foreign Investment Company (PFIC) Purging Elections Rule This document contains final regulations that provide certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of section 1291 of the Internal Revenue Code even though the foreign corporation in which they own stock is no longer treated as a PFIC under section 1297(a) or (e) of the Code. 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. 2007-09-27 2007 9 https://www.federalregister.gov/documents/2007/09/27/E7-18988/guidance-on-passive-foreign-investment-company-pfic-purging-elections https://www.govinfo.gov/content/pkg/FR-2007-09-27/pdf/E7-18988.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final regulations that provide certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of section 1291 of the Internal Revenue Code even though the foreign corporation in which they own...  

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