The deferred-tax-charge regime applies if the shareholder either does not make a QEF
election or makes one after the first year of owning PFIC stock.
Provided a taxpayer has not made a QEF
or mark-to-market election, taxation under the PFIC regime hinges on the allocation of an "excess distribution" (which, despite the name, includes gain from the disposition of stock in a PFIC) to the taxpayer's holding period for such stock.
Observation: Generally, a taxpayer should make a QEF
election if possible.
Because they were unaware of the corporation's PFIC status, they failed to make a QEF
person did not make a QEF
election for the first year in which the foreign corporation became a PFIC.
This election purges the PFIC taint by recognizing gain, and paying tax and interest under the PFIC rules, as though the shares were sold at fair market value (FMV) on the first day of the PFIC's tax year for which the shareholder also makes a QEF
In this particular situation, the QEF
election may have alleviated such a result.
On his part, QEF
president al-Attiyah thanked QNB officials for the ceremony held for the Qatari team, stressing that this honouring ceremony will serve as support and incentive for the team, especially from a financial institution of such local and international prominence.
These statements contain information that will enable US taxpayers to elect to treat these funds as QEFs
should they choose to do so based on the advice of their tax advisor in light of their tax circumstances.
shareholders need not file the form unless they are treated as receiving excess distributions, making an election, or have an inclusion (either because of a QEF
or mark-to-market election), essentially the same obligations as before the enactment of section 1298(f).
The regulations further provide that distributions of earnings and profits previously taxed as subpart F or QEF
inclusions that are not treated as dividends for income tax purposes are treated as dividends for purposes of the net investment income tax.
As an F-14 Tomcat squadron, VF-2 flew more than 4,000 flight hours during Operations Desert Storm, 01F, and QEF