26 C.F.R. § 1.1298-3T Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC (temporary).
Title 26 - Internal Revenue
(a) through (d) [Reserved] For further guidance, see §1.1298–0, the entries for §1.1298–3T(a) through (d). (e) Late purging elections requiring special consent. (1) In general. (2) Prejudice to the interests of the U.S. government. (3) Procedural requirement. (4) Time and manner of making late election. (f) Effective date. [T.D. 9232, 70 FR 72913, Dec. 8, 2005]
Title 26: Internal Revenue
PART 1—INCOME TAXES
Special Rules for Determining Capital Gains and Losses
§ 1.1298-3T Deemed sale or deemed dividend election by a U.S. person that is a shareholder of a former PFIC (temporary).