26 C.F.R. § 1.853-4 Manner of making election.
Title 26 - Internal Revenue
(a) General rule. A regulated investment company, to make a valid election under section 853, must— (1) File with Form 1099 and Form 1096 a statement as part of its return which sets forth the following information: (i) The total amount of income received from sources within foreign countries and possessions of the United States; (ii) The total amount of income, war profits, or excess profits taxes (described in section 901(b)(1)) paid, or deemed to have been paid under the provisions of any treaty to which the United States is a party, to such foreign countries or possessions; (iii) The date, form, and contents of the notice to its shareholders; (iv) The proportionate share of such taxes paid during the taxable year and foreign income received during such year attributable to one share of stock of the regulated investment company; and (2) File as part of its return for the taxable year a Form 1118 modified so that it becomes a statement in support of the election made by a regulated investment company for taxes paid to a foreign country or a possession of the United States. (b) Irrevocability of the election. The election is applicable only with respect to taxable years subject to the Code, shall be made with respect to all such foreign taxes, and must be made not later than the time prescribed for filing the return (including extensions thereof). Such election, if made, shall be irrevocable with respect to the dividend (or portion thereof), and the foreign taxes paid with respect thereto, to which the election applies.
Title 26: Internal Revenue
PART 1—INCOME TAXES
REGULATED INVESTMENT COMPANIES AND REAL ESTATE INVESTMENT TRUSTS
§ 1.853-4 Manner of making election.
