For Tax Professionals  
T.D. 8750 December 31, 1997

General Rules for Making & Maintaining Qualified
Electing Fund Elections

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1 and 602 [TD 8750] RIN 1545-AV40

TITLE: General Rules for Making and Maintaining Qualified Electing Fund Elections

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Temporary and final regulations.

SUMMARY: This document contains temporary regulations that provide guidance to a passive foreign investment company (PFIC) shareholder that makes the election under section 1295 (section 1295 election) to treat the PFIC as a qualified electing fund (QEF). This document also contains temporary regulations that provide guidance for shareholders that wish to make a section 1295 election that will apply on a retroactive basis (retroactive election). In addition, this document contains a temporary regulation that provides guidance under section 1291 to a PFIC shareholder that is a tax-exempt organization. Temporary regulations are needed to provide taxpayers additional time to satisfy certain requirements to make the section 1295 election. The text of these temporary regulations also serves as the text of proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. In addition, this document removes  1.1291-9(i)(1) of the final regulations, and amends  1.1297-3T. References to sections 1296 and 1297 in this document are references to sections 1296 and 1297 as in effect before the effective date of section 1122(a) of the Tax Relief Act of 1997.

DATES: These regulations are effective January 2, 1998. For dates of applicability, see 1.1291-1T(e)(2), 1.1293- 1T(a)(2)(ii), 1.1293-1T(c)(3), 1.1295-1T(k), 1.1295-3T(h), and  1.1297-3T(c)(3) of these regulations.

FOR FURTHER INFORMATION CONTACT: Gayle Novig, (202) 622-3840 (not a toll-free number).

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