Tax treatment liquidating distribution pfic dating sites in saskatoon


29-Jul-2020 18:41

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For dispositions of stock of a section 1291 fund that qualify for nonrecognition treatment, see section 1.1291-6.

Gain is determined on a share-by- share basis and is taxed as an excess distribution as provided in section 1.1291-2(e)(2).

In Notice 2011-55, the IRS announced its intention to issue more regulations under Section 1298(f) and to revise Form 8621.

The 2011 Notice suspended Section 1298(f) reporting until the new form was released.

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

New Regulations The temporary regulations generally incorporate definitional provisions of the 1992 proposed regulations, with updates for subsequent statutory changes. With some exceptions, this filing requirement applies to domestic estates, nongrantor trusts and U. persons treated as owners of any domestic or foreign grantor trust.

The temporary regulations further provide that the stock attribution rules apply to both domestic and foreign entities, including special rules for grantor and nongrantor trusts (e.g., each beneficiary of a domestic or foreign estate or nongrantor trust is considered to own a proportionate share of the stock held by the estate or trust). Regulatory exceptions to the Section 1298(f) requirement include categorical exceptions (e.g., for tax-exempt organizations or individual retirement plans), as well as quantitative filing thresholds.

Background A foreign corporation is a PFIC if either (i) 75 percent or more of its gross income is passive income or (ii) 50 percent or more of the average value of its assets comprises assets that produce passive income.

Currently, the Code has three sets of rules to penalize and/or prevent income tax deferral by U. owners of PFICs: (1) the default, excess distribution regime of Section 1291, (2) the qualified electing fund (QEF) regime of Section 1293 and (3) the mark-to-market (MTM) regime of Section 1296.

The HIRE Act of 2010 added Section 1298(f), requiring any U. shareholder of a PFIC to file an annual report and extending the limitations period on assessment for failure to comply.



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