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PFIC Regulations Map

  1. IRC § 1291: Interest on tax deferral
    1. 26 CFR 1.1291-1: Taxation of U.S. Persons that are shareholders of PFICs that are not pedigreed QEFs
    2. 26 CFR 1.1291-9: Deemed dividend election
    3. 26 CFR 1.1291-10: Deemed sale election
  2. IRC § 1293: Current taxation of income from a qualified electing fund
    1. 26 CFR 1.1293-1: Current taxation of income from qualified electing funds
  3. IRC § 1294: Election to extend time for payment of tax on undistributed earnings
    1. 26 CFR 1.1294-1T: Election to extend the time for payment of tax on undistributed earnings of a qualified electing fund
  4. IRC § 1295: Qualified electing funds
    1. 26 CFR 1.1295-1: Qualified electing funds
    2. 26 CFR 1.1295-3: Retroactive elections
  5. IRC § 1296: Election of Mark to market for marketable stock
    1. 26 CFR 1.1296-1: Mark to market election for marketable stock
    2. 26 CFR 1.1296-2: Definition of marketable stock
  6. IRC § 1297: Passive Foreign Investment Company
    1. 26 CFR 1.1297-3: Deemed sale or deemed dividend election by u.s. person that is a shareholder of section 1297(e) PFIC
  7. IRC § 1298: Special Rules
    1. 26 CFR 1.1298-1T: Section 1298(f) reporting requirements for U.S. persons that are shareholders of a passive foreign investment company.
    2. 26 CFR 1.1298-3: Section 1298-3 Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC.