Webyour personal tax circumstances, to elect to treat the Fund as a qualified electing fund(“QEF”). Generally, a QEF election is madeon Form 8621 (“Return by aShareholder of a Passive Foreign InvestmentCompany or Qualified ElectingFund”) and is filed for each fund for which you wish to make a QEF election. WebQualified Electing Fund Documentation.....44 SECTION 6.11. See Part IV of Form 8621, Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund . If such an investor chooses to make a Qualified Electing Fund (“QEF”) election with respect to such fund, he or she will generally be taxed on a flow through basis ...
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Web26 U.S. Code § 1295 - Qualified electing fund U.S. Code Notes prev next (a) General rule For purposes of this part, any passive foreign investment company shall be treated as a … WebNov 23, 2016 · If the PFIC is not a CFC and subject to the rules just mentioned, the U.S. shareholder generally has three options: Qualified electing fund (IRC § 1293) 1) Elect to treat the PFIC as a qualified electing fund (QEF) for a direct or indirect ownership share. hashing llc
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WebA PFIC QEF is a type of investment fund that is organized under the laws of a foreign country and invests in U.S. securities. The fund is considered a passive investment vehicle and is … Web26 CFR § 1.1295-1 - Qualified electing funds. CFR Table of Popular Names prev next § 1.1295-1 Qualified electing funds. (a) In general. [Reserved] (b) Application of section 1295 election. [Reserved] (1) Election personal to shareholder. [Reserved] (2) Election applicable to specific corporation only - (i) In general. [Reserved] WebJun 25, 2016 · A QEF (Qualifying Electing Fund) election allows a PFIC to be treated essentially the same as a partnership in that income is taxed at the ordinary income tax rate and capital gains are treated as capital gains. This is generally more favorable than a mark-to-market (MTM) election or the default punitive rules under Section 1291. hashing linear probing java