Tax treatment liquidating distribution pfic

Rated 4.53/5 based on 857 customer reviews

The OFR/GPO partnership is committed to presenting accurate and reliable regulatory information on Federal with the objective of establishing the XML-based Federal Register as an ACFR-sanctioned publication in the future.

While every effort has been made to ensure that the material on Federal is accurately displayed, consistent with the official SGML-based PDF version on, those relying on it for legal research should verify their results against an official edition of the Federal Register.

tax treatment liquidating distribution pfic-40

tax treatment liquidating distribution pfic-39

tax treatment liquidating distribution pfic-17

tax treatment liquidating distribution pfic-16

(Emphasis added) Some individuals believe that the bolded text prevents a loss from being recognized upon the disposition of stock of a section 1291 fund.The new rules also address filing requirements under Section 1298(f). For example, an individual need not file Form 8621 if he or she is not subject to tax under Section 1291 and either (i) the value of all PFIC stock owned by the individual does not exceed ,000; or (ii) the PFIC stock is owned by the individual through another PFIC, and the value of the shareholder’s share of the high-tier PFIC’s interest in the lower-tier PFIC does not exceed ,000.The new rules apply only to annual reporting under Section 1298(f) for years ending on or after December 31, 2013.This site displays a prototype of a “Web 2.0” version of the daily Federal Register.It is not an official legal edition of the Federal Register, and does not replace the official print version or the official electronic version on GPO’s

Leave a Reply