QEF election for PFICs – Election to extend the time for payment of tax on undistributed earnings of a qualified electing fund (temporary).

PFICS and QEF Elections, U.S. Tax Planning /

(a) Purpose and scope. This section provides rules for making the annual election under section 1294. Under that section, a U.S. person that is a shareholder in a qualified electing fund (QEF) may elect to extend the time for payment of its tax liability which is attributable to its share of the undistributed earnings of the QEF. In general, a QEF is a passive foreign investment company (PFIC), as defined in section 1296, […]

QEF election for PFICs – Election to extend the time for payment of tax on undistributed earnings of a qualified electing fund (temporary). Read More »