26 C.F.R. § 1.1298-3   Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC.


Title 26 - Internal Revenue


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

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§ 1.1298-3   Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC.

(a) In general.

(b) Application of deemed sale election rules.

(1) Eligibility to make the deemed sale election.

(2) Effect of deemed sale election.

(3) Time for making the deemed sale election.

(4) Manner of making the deemed sale election.

(5) Adjustments to basis.

(6) Treatment of holding period.

(c) Application of deemed dividend election rules.

(1) Eligibility to make the deemed dividend election.

(2) Effect of the deemed dividend election.

(3) Post-1986 earnings and profits defined.

(4) Time for making the deemed dividend election.

(5) Manner of making the deemed dividend election.

(6) Adjustments to basis.

(7) Treatment of holding period.

(8) Coordination with section 959(e).

(d) Termination date.

(e) Late purging elections requiring special consent. [Reserved] For further guidance, see §1.1298–0T.

(f) Effective date.

[T.D. 9231, 70 FR 72915, Dec. 8, 2005]

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