26 C.F.R. § 1.1291-9T   Deemed dividend election (temporary).


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
Special Rules for Determining Capital Gains and Losses

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§ 1.1291-9T   Deemed dividend election (temporary).

(a) through (j)(2)(iv) [Reserved] For further guidance, see §1.1291–9(a) through (j)(2)(iv).

(j)(2)(v) Section 1297(e) PFIC. A foreign corporation is a section 1297(e) PFIC with respect to a shareholder (as defined in §1.1291–9(j)(3)) if:

(A) The foreign corporation qualifies as a PFIC under section 1297(a) on the first day on which the qualified portion of the shareholder's holding period in the foreign corporation begins, as determined under section 1297(e)(2); and

(B) The stock of the foreign corporation held by the shareholder is treated as stock of a PFIC, pursuant to section 1298(b)(1), because, at any time during the shareholder's holding period of the stock, other than the qualified portion, the corporation was a PFIC that was not a QEF.

(3) [Reserved] For further guidance, see §1.1291–9(j)(3).

(k) Effective date. (1) The rules of this section are applicable as of December 8, 2005.

(2) The applicability of this section will expire on or before December 8, 2008.

[T.D. 9232, 70 FR 72910, Dec. 8, 2005]

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