Passive Foreign Investment Companies

Internal Revenue Code

Treasury Regulations

T.D. 9231 (Final regulations on PFIC purging elections) (December 8, 2005)

T.D. 9232 (Temporary regulations on late PFIC purging elections) (December 8, 2005)

Final Regulations:  Electing Mark to Market for Marketable Stock (T.D. 9123, May 3, 2004)

Private Letter Rulings

PLR 200420025 (Consent granted to make retroactive QEF election)

PLR 200420023 (Consent granted to make retroactive QEF election)

Relevant IRS Forms

Form 8621 Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund (Rev. December 2004)

Form 8621-A Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company (December 2005)

Instructions for Form 8621-A Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company (December 2005)

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