§ 1.1291-0T - Passive foreign investment company—table of contents (temporary).  


Latest version.
  • This section lists the table of contents for §§1.1291-1T and 1.1291-9T.

    §1.1291-1T   Taxation of United States persons that are shareholders of section 1291 funds (temporary).

    (a) through (b)(2)(i) [Reserved]

    (ii) Pedigreed QEF.

    (b)(2)(iii) and (iv) [Reserved]

    (v) Section 1291 fund.

    (3) through (6) [Reserved]

    (7) Shareholder.

    (8) Indirect shareholder.

    (i) In general.

    (ii) Ownership through a corporation.

    (A) Ownership through a non-PFIC foreign corporation.

    (B) Ownership through a PFIC.

    (C) Ownership through a domestic corporation.

    (iii) Ownership through pass-through entities.

    (A) Partnerships.

    (B) S Corporations.

    (C) Estates and nongrantor trusts.

    (D) Grantor trusts.

    (c) through (j) [Reserved]

    (k) Effective/applicability dates.

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

    (a) through (j)(2) [Reserved]

    (3) Shareholder.

    (k) Effective/applicability date.

    [T.D. 9650, 78 FR 79607, Dec. 31, 2013]