General Rules for Making &
Maintaining Qualified Electing Fund Elections

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Parts 1 and 602 [TD 8870] RIN 1545-
AV39

TITLE: General Rules for Making and Maintaining Qualified Electing
Fund Elections

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations that provide
guidance to a passive foreign investment company (PFIC) shareholder
that makes the election under section 1295 (section 1295 election)
to treat the PFIC as a qualified electing fund (QEF), and for PFIC
shareholders that wish to make a section 1295 election that will
apply on a retroactive basis (retroactive election). In addition,
this document contains a final regulation that provides guidance
under section 1291 to a PFIC shareholder that is a tax-exempt
organization. Lastly, this document contains final regulations under
section 1293 for calculating and reporting net capital gain by a
QEF, and also clarifies the application of the current income
inclusion rules of section 1293 to interest in a QEF held through a
domestic pass through entity.

DATES: Effective Date. These regulations are effective February 7,
2000. Applicability Date. In general, these regulations are
applicable as of January 2, 1998. For special dates of applicability
see �1.1295-1(k).

FOR FURTHER INFORMATION CONTACT: Margaret A. Fung, (202) 622-3840
(not a toll free number).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collections of information in these final regulations have been
reviewed and approved by the Office of Management and Budget in
accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. 3507)
under control number 1545 - 1555. Responses to these collections of
information are mandatory for PFIC shareholders that wish to make
the section 1295 election to treat the PFIC as a QEF. Comments on
the collections of information should be sent to the Office of
Management and Budget , Attn: Desk Officer for the Department of the
Treasury, Office of Information and Regulatory Affairs, Washington,
DC 20503, with copies to the Internal Revenue Service , Attn: IRS
Reports Clearance Officer, OP:FS:FP, Washington, DC 20224.

The estimated average annual burden per respondent and/or
recordkeeper varies from fifteen minutes to three hours, depending
on individual circumstances, with an estimated average of twenty-
nine minutes. An agency may not conduct or sponsor, and a person is
not required to respond to, a collection of information unless the
collection of information displays a valid control number assigned
by the Office of Management and Budget. Books or records relating to
a collection of information must be retained as long as their
contents may become material in the administration of any internal
revenue law. Generally, tax returns and tax return information are
confidential, as required by 26 U.S.C. 6103.

Background

On January 2, 1998, the Treasury and the IRS published temporary
regulations regarding the section 1295 election and rules applicable
to a PFIC shareholder under sections 1291, 1293, 1295 and 1297
(redesignated as section 1298 by the Taxpayer Relief Act of 1997,
and hereafter referred to as section 1298) (TD 8750, 63 FR 6). On
that same date, the Treasury and the IRS published a notice of
proposed rulemaking in the Federal Register (63 FR 35). The text of
the temporary regulations served as the text of the proposed
regulations.

Sections 1291, 1293, 1295 and 1298 were added by the Tax Reform Act
of 1986, effective for taxable years of foreign corporations
beginning after December 31, 1986. As originally enacted, the
section 1295 election was an election made by the PFIC. The
Technical and Miscellaneous Revenue Act of 1988 (TAMRA) amended
section 1295, effective for taxable years of foreign corporations
beginning after December 31, 1986, to change the section 1295
election to a shareholder-by-shareholder election. Sections 1291,
1293 and 1298 were also amended by TAMRA, and sections 1293 and 1298
were further amended by the Omnibus Budget Reconciliation Act of
1993. Section 1298 also was amended by the Revenue Reconciliation
Act of 1989 and the Small Business Job Protection Act of 1996. In
addition, the Taxpayer Relief Act of 1997 (1997 TRA) amended section
1 to provide categories of long-term capital gain and the maximum
rates of tax to which the categories are subject. In certain cases,
this amendment affects the calculation of net capital gain for
purposes of section 1293.

No written comments were received on the proposed regulations, and
no public hearing was requested or held. The proposed regulations
are adopted as final regulations as revised by this Treasury
Decision. The revisions are summarized in the explanations below.

Explanation of Revisions

A foreign corporation is a PFIC for a taxable year if the foreign
corporation satisfies either the income or asset test of section
1297(a) for that year. A foreign corporation is a PFIC under the
income test if 75 percent or more of its gross income for its
taxable year is passive, or investment-type, income. Alternatively,
under the asset test, a foreign corporation is a PFIC if 50 percent
or more of the average fair market value of its assets during its
taxable year are assets that produce or are held for the production
of passive income. A shareholder of a foreign corporation that
qualifies as a PFIC is subject to the interest charge regime of
section 1291 with respect to certain distributions by the PFIC and
certain dispositions of its stock. Generally, a shareholder of a
PFIC may avoid the interest charge regime by making a timely
election under section 1295 to treat a PFIC as a QEF, in which case
the shareholder will be taxed annually pursuant to section 1293 on
its pro rata share of the ordinary earnings and net capital gain of
the PFIC. Under section 1295(a), a section 1295 election will apply
with respect to the PFIC if the PFIC complies with requirements
prescribed by the Secretary for purposes of determining the ordinary
earnings and net capital gain of the PFIC and otherwise carrying out
the purposes of the PFIC provisions.

Section 1295(b)(1), as enacted by TAMRA, provides that a shareholder
may make a section 1295 election with respect to a PFIC for any
taxable year of the shareholder (shareholder election year). Once
made, the election will apply to that year and to all subsequent
years of the shareholder unless revoked by the shareholder with the
consent of the Secretary. Section 1295(b)(2) prescribes the time for
making the election. In general, for the section 1295 election to be
applicable to a taxable year, the shareholder must make the election
by the due date, as extended under section 6081, for the
shareholder's return for that taxable year. However, to the extent
provided in the regulations, a section 1295 election may be made for
a taxable year after the prescribed due date if the shareholder
failed to make a timely election because the shareholder reasonably
believed that the foreign corporation was not a PFIC.

Under temporary regulations �1.1295-1T(d)(1) and (f)(1), the
shareholder, as defined in �1.1291-9(j)(3), of a PFIC makes the
section 1295 election by filing a Form 8621 with the shareholder's
Federal income tax return by the election due date for the
shareholder election year, and by filing a copy of that form with
the Philadelphia Service Center. In addition, under temporary
regulation �1.1295-1T(f)(2), the shareholder must file an annual
Form 8621 with its Federal income tax return to report the
shareholder's pro rata share of the ordinary earnings and net
capital gain of the QEF. Temporary regulation �1.1295-1T(f)(2) also
required that a copy of the annual Form 8621 be filed with the
Philadelphia Service Center. To reduce taxpayer burden, this final
regulation eliminates the requirement for filing a copy of Form 8621
with the Philadelphia Service Center when the shareholder makes the
section 1295 election or reports the shareholder's annual pro rata
share of the ordinary earnings and net capital gain of the QEF.

In addition, this final regulation clarifies the rule in temporary
regulation �1.1295- 1T(c)(2)(ii) for income inclusion by the
shareholder of a QEF under section 1293 for any taxable year that
the foreign corporation is not a PFIC under section 1297(a) and is
not treated as a PFIC under section 1298(b)(1). This final
regulation clarifies that in such case, the shareholder is not
required to include pursuant to section 1293 the shareholder's pro
rata share of ordinary earnings and net capital gain for such year,
and the shareholder shall not be required to satisfy the section
1295 annual reporting requirement for such year. Cessation of a
foreign corporation's status as a PFIC will not, however, terminate
a section 1295 election. Thus, if the foreign corporation is a PFIC
in any taxable year after a year in which it is not treated as a
PFIC, the shareholder's original election under section 1295
continues to apply and the shareholder must take into account its
pro rata share of ordinary earnings and net capital gain for such
year and comply with the section 1295 annual reporting requirement.

The Taxpayer Relief Act of 1997 added section 1296 to provide PFIC
shareholders with an alternative method for current income inclusion
by making a mark-to- market election with respect to their PFIC
stock that qualifies as marketable stock. The election is available
to shareholders whose taxable years begin after December 31, 1997
for stock in a foreign corporation whose taxable year ends with or
within the shareholder's taxable year. The effect of a mark-to-
market election on a section 1295 election will be addressed in
subsequent regulations under section 1296. In addition, temporary
regulation �1.1297-3T(c) governing the deemed dividend election by a
United States person that is a shareholder of a PFIC will be
finalized in a future regulation project.

Notice 98-22 (1998-17 I.R.B. 5) provides that taxpayers will be
permitted to apply the rules of the temporary regulations under
�1.1295-1T(b)(4) (section 1295 election by shareholders who file a
joint return) and �1.1295-1T(f) and (g) (procedures for making a
section 1295 election and annual information requirements by the
PFIC or intermediary) to taxable years beginning before January 1,
1998, for which the statute of limitations on the assessment of tax
has not expired and, with respect to � 1.1295- 1T(b)(4), if certain
consistency requirements are met. The rule of Notice 98-22 has been
incorporated into �1.1295-1(k) of this regulation. Final regulation
�1.1295-1(k) is changed to reflect the special effective dates for
�1.1295-1(b)(4), (f) and (g) as provided by Notice 98-22.
Accordingly, Notice 98-22 is obsoleted since the effective date
provisions are contained in this final regulation.

Notice 88-125 described the requirements a shareholder must satisfy
to make and maintain a section 1295 election for taxable years
beginning before January 1, 1998. As a result of the procedures and
requirements set forth first in the temporary regulations published
on January 2, 1998, and now in these final regulations, Notice
88-125 is obsoleted effective February 7, 2000.

Effect On Other Documents

Notice 88-125 and Notice 98-22 are obsoleted as of February 7, 2000.

Special Analyses

It has been determined that the final regulations are not a
significant regulatory action as defined in Executive Order 12866.
Therefore, a regulatory assessment is not required. It has also been
determined that section 553(b) of the Administrative Procedure Act
(5 U.S.C. chapter 5) does not apply to these regulations. Further,
it is hereby certified, pursuant to sections 603(a) and 605(b) of
the Regulatory Flexibility Act (5 U.S.C. chapter 6), that the
collection of information contained in these regulations will not
have a significant economic impact on substantial number of small
entities. The cost of collection of information to small entities is
insignificant because the primary reporting burden is on individual
PFIC shareholders who make the section 1295 election. Therefore, the
collection of information will not have a substantial economic
impact. Therefore, a regulatory flexibility analysis under the
Regulatory Flexibility Act is not required. Pursuant to section
7805(f) of the Internal Revenue Code, the notice of proposed
rulemaking preceding these regulations was submitted to the Chief
Counsel for Advocacy of the Small Business Administration for
comment on its impact on small business.

Drafting Information

The principal author of the final regulations is Margaret A. Fung,
Office of Associate Chief Counsel (International). However, other
personnel from the IRS and Treasury Department participated in their
development.

List of Subjects

26 CFR Part 1 Income taxes, Reporting and recordkeeping
requirements.

26 CFR Part 602 Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations Accordingly, 26 CFR parts
1 and 602 are amended as follows:

PART 1-INCOME TAXES

Paragraph 1. The authority citation for part 1 is amended by adding
entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

Sec. 1.1291-1 also issued under 26 U.S.C. 1291. * * *

Sec. 1.1293-1 also issued under 26 U.S.C. 1293. * * *

Sec. 1.1295-3 also issued under 26 U.S.C. 1295. * * *

�1.1291-1T [Redesignated as �1.1291-1 ]

Par. 2. Section 1.1291-1T is redesignated as �1.1291-1 and the
section heading is revised to read as follows:

�1.1291-1 Taxation of U.S. persons that are shareholders of PFICs
that are not pedigreed QEFs.

* * * * *

Par. 3. Section 1.1293-1T is redesignated as �1.1293-1 and the newly
designated section is amended by revising the section heading and
the first sentence of paragraph (c)(1) to read as follows:

�1.1293-1 Current taxation of income from qualified electing funds.

* * * * *

(c) Application of rules of inclusion with respect to stock held by
a pass through entity -- (1) In general. If a domestic pass through
entity makes a section 1295 election, as provided in paragraph (d)
(2) of this section, with respect to the PFIC shares that it owns,
directly or indirectly, the domestic pass through entity takes into
account its pro rata share of the ordinary earnings and net capital
gain attributable to the QEF shares held by the pass through entity.
* * *

* * * * *

Par. 4. Section 1.1295-0 is amended by:

1. Revising the introductory text of the section.

2. Removing the entry for the heading of �1.1295-1T and adding an
entry for the heading of �1.1295-1 in its place.

3. Revising the entries for �1.1295-1(d)(3) through (d)(5).

4. Adding entries for �1.1295-1(d)(6) and (e)(1) and (e)(2).

5. Removing the entry for the heading of �1.1295-3T and adding an
entry for the heading of �1.1295-3 in its place.

The revisions and additions read as follows:

�1.1295-0 Table of contents. This section contains a listing of the
headings for ��1.1295-1 and 1.1295-3. �1.1295-1 Qualified electing
funds.

* * * * *

(d) * * *

(3) Indirect ownership of a PFIC through other PFICs.

(4) Member of consolidated return group as shareholder.

(5) Option holder.

(6) Exempt organization.

(e) * * *

(1) General rule.

(2) Examples.

* * * * *

�1.1295-3 Retroactive elections.

* * * * *

�1.1295-1T [Redesignated as �1.1295-1 ] Par. 5. Section �1.1295-1T
is redesignated as �1.1295-1 and the newly designated section is
amended by:

1. Revising the section heading.

2. Revising paragraph (b)(3)(iv)(B).

3. Adding paragraph (b)(3)(v).

4. Adding a sentence to the end of paragraph (b)(4).

5. Revising paragraphs (c)(2)(ii) and (iii).

6. Revising the third sentence in paragraph (c)(2)(v) Example 3.

7. Redesignating paragraphs (d)(3), (d)(4) and (d)(5) as paragraphs
(d)(4), (d)(5) and (d)(6), respectively.

8. Adding a new paragraph (d)(3).

9. Revising paragraph (e).

10. In the last sentence of paragraph (f)(1)(iii), the language
"capital gain; and" is removed and the language "capital gain." is
added in its place.

11. Adding the word "and" at the end of paragraph (f)(1)(ii).

12. Removing paragraph (f)(1)(iv).

13. Adding the word "and" at the end of paragraph (f)(2)(i)(B).

14. In the last sentence of paragraph (f)(2)(i)(C), the language
"capital gain; and" is removed and the language "capital gain." is
added in its place.

15. Removing paragraph (f)(2)(i)(D).

16. Adding a new paragraph (f)(3).

17. Revising the introductory language of paragraph (g)(3).

18. Adding paragraph (g)(5).

19. Revising the first sentence of paragraph (h).

20. Revising paragraph (k). The revisions and additions read as
follows: �1.1295-1 Qualified electing funds.

* * * * *

(b) * * *

(3) * * *

(iv) * * *

(B) In the case of PFIC stock transferred by an interest holder or
beneficiary to a pass through entity in a transaction in which gain
is not fully recognized (including pursuant to regulations under
section 1291(f)), the pass through entity makes the section 1295
election with respect to the PFIC stock transferred for the taxable
year in which the transfer was made. The PFIC stock transferred will
be treated as stock of a pedigreed QEF by the pass through entity,
however, only if that stock was treated as stock of a pedigreed QEF
with respect to the interest holder or beneficiary at the time of
the transfer, and the PFIC has been a QEF with respect to the pass
through entity for all taxable years of the PFIC that are included
wholly or partly in the pass through entity's holding period of the
PFIC stock during which the foreign corporation was a PFIC within
the meaning of �1.1291-9(j).

(v) Characterization of stock distributed by a partnership. In the
case of PFIC stock distributed by a partnership to a partner in a
transaction in which gain is not fully recognized, the PFIC stock
will be treated as stock of a pedigreed QEF by the partners only if
that stock was treated as stock of a pedigreed QEF with respect to
the partnership for all taxable years of the PFIC that are included
wholly or partly in the partnership's holding period of the PFIC
stock during which the foreign corporation was a PFIC within the
meaning of �1.1291-9(j), and the partner has a section 1295 election
in effect with respect to the distributed PFIC stock for the
partner's taxable year in which the distribution was made. If the
partner does not have a section 1295 election in effect, the stock
shall be treated as stock in a section 1291 fund. See paragraph (k)
of this section for special applicability date of paragraph (b)(3)
(v) of this section.

(4) * * * See paragraph (k) of this section for special
applicability date of paragraph (b)(4) of this section.

(c) * * *

(2) * * *

(ii) Effect of PFIC status on election. A foreign corporation will
not be treated as a QEF for any taxable year of the foreign
corporation that the foreign corporation is not a PFIC under section
1297(a) and is not treated as a PFIC under section 1298(b)(1).
Therefore, a shareholder shall not be required to include pursuant
to section 1293 the shareholder's pro rata share of ordinary
earnings and net capital gain for such year and shall not be
required to satisfy the section 1295 annual reporting requirement of
paragraph (f)(2) of this section for such year. Cessation of a
foreign corporation's status as a PFIC will not, however, terminate
a section 1295 election. Thus, if the foreign corporation is a PFIC
in any taxable year after a year in which it is not treated as a
PFIC, the shareholder's original election under section 1295
continues to apply and the shareholder must take into account its
pro rata share of ordinary earnings and net capital gain for such
year and comply with the section 1295 annual reporting requirement.

(iii) Effect on election of complete termination of a shareholder's
interest in the PFIC. Complete termination of a shareholder's direct
and indirect interest in stock of a foreign corporation will not
terminate a shareholder's section 1295 election with respect to the
foreign corporation. Therefore, if a shareholder reacquires a direct
or indirect interest in any stock of the foreign corporation, that
stock is considered to be stock for which an election under section
1295 has been made and the shareholder is subject to the income
inclusion and reporting rules required of a shareholder of a QEF. *
* * * *

(v) * * *

Example 3. * * * If P does not make the section 1295 election with
respect to the FC stock, C will continue to be subject, in C's
capacity as an indirect shareholder of FC, to the income inclusion
and reporting rules required of shareholders of QEFs in 1999 and
subsequent years for that portion of the FC stock C is treated as
owning indirectly through the partnership. * * *

(d) * * *

(3) Indirect ownership of a PFIC through other PFICs -- (i) In
general. An election under section 1295 shall apply only to the
foreign corporation for which an election is made. Therefore, if a
shareholder makes an election under section 1295 to treat a PFIC as
a QEF, that election applies only to stock in that foreign
corporation and not to the stock in any other corporation which the
shareholder is treated as owning by virtue of its ownership of stock
in the QEF.

(ii) Example. The following example illustrates the rules of
paragraph (d)(3)(i) of this section:

Example. In 1988, T, a U.S. person, purchased stock of FC, a foreign
corporation that is a PFIC. FC also owns the stock of SC, a foreign
corporation that is a PFIC. T makes an election under section 1295
to treat FC as a QEF. T's section 1295 election applies only to the
stock T owns in FC, and does not apply to the stock T indirectly
owns in SC.

*****

(e) Time for making a section 1295 election -- (1) In general.
Except as provided in �1.1295-3, a shareholder making the section
1295 election must make the election on or before the due date, as
extended under section 6081 (election due date), for filing the
shareholder's income tax return for the first taxable year to which
the election will apply. The section 1295 election must be made in
the original return for that year, or in an amended return, provided
the amended return is filed on or before the election due date.

(2) Examples. The following examples illustrate the rules of
paragraph (e)(1) of this section:

Example 1. In 1998, C, a domestic corporation, purchased stock of
FC, a foreign corporation that is a PFIC. Both C and FC are calendar
year taxpayers. C wishes to make the section 1295 election for its
taxable year ended December 31, 1998. The section 1295 election must
be made on or before March 15, 1999, the due date of C's 1998 income
tax return as provided by section 6072(b). On March 14, 1999, C
files a request for a three-month extension of time to file its 1998
income tax return under section 6081(b). C's time to file its 1998
income tax return and to make the section 1295 election is thereby
extended to June 15, 1999.

Example 2. The facts are the same as in Example 1 except that on May
1, 1999, C filed its 1998 income tax return and failed to include
the section 1295 election. C may file an amended income tax return
for 1998 to make the section 1295 election provided the amended
return is filed on or before the extended due date of June 15, 1999.

* * * * *

(f) * * *

(3) Effective date. See paragraph (k) of this section for special
applicability date of paragraph (f) of this section.

(g) * * *

(3) Annual Intermediary Statement. In the case of a U.S. person that
is an indirect shareholder of a PFIC that is owned through an
intermediary, as defined in paragraph (j) of this section, an Annual
Intermediary Statement issued by an intermediary containing the
information described in paragraph (g)(1) of this section and
reporting the indirect shareholder's pro rata share of the ordinary
earnings and net capital gain of the QEF as described in paragraph
(g)(1)(ii)(A) of this section, may be provided to the indirect
shareholder in lieu of the PFIC Annual Information Statement if the
following conditions are satisfied --

* * * * *

(5) Effective date. See paragraph (k) of this section for special
applicability date of paragraph (g) of this section. (h) Transition
rules. Taxpayers may rely on Notice 88-125 (1988-2 C.B. 535) (see
�601.601(d)(2) of this chapter), for rules on making and maintaining
elections for shareholder election years (as defined in paragraph
(j) of this section) beginning after December 31, 1986, and before
January 1, 1998. * * *

* * * * *

(k) Effective dates. Paragraphs (b)(2)(iii), (b)(3), (b)(4) and (c)
through (j) of this section are applicable to taxable years of
shareholders beginning after December 31, 1997. However, taxpayers
may apply the rules under paragraphs (b)(4), (f) and (g) of this
section to a taxable year beginning before January 1, 1998, provided
the statute of limitations on the assessment of tax has not expired
as of April 27, 1998 and, in the case of paragraph (b)(4) of this
section, the taxpayers who filed the joint return have consistently
applied the rules of that section to all taxable years following the
year the election was made. Paragraph (b)(3)(v) of this section is
applicable as of February 7, 2000, however a taxpayer may apply the
rules to a taxable year prior to the applicable date provided the
statute of limitations on the assessment of tax for that taxable
year has not expired.

�1.1295-3T [Redesignated as �1.1295-3 ] Par. 6. Section �1.1295-3T
is redesignated as �1.1295-3 and the newly designated section is
amended by revising the section heading and paragraphs (b)(1) and
(c)(5)(i) to read as follows: �1.1295-3 Retroactive elections.

* * * * *

(b) * * *

(1) Reasonably believed, within the meaning of paragraph (d) of this
section, that as of the election due date, as defined in �
1.1295-1(e), the foreign corporation was not a PFIC for its taxable
year that ended during the retroactive election year;

* * * * *

(c) * * *

(5) Time of and manner for filing a Protective Statement--(i) In
general. Except as provided in paragraph (c)(5)(ii) of this section,
a Protective Statement must be attached to the shareholder's federal
income tax return for the shareholder's first taxable year to which
the Protective Statement will apply. The shareholder must file its
return and the copy of the Protective Statement by the due date, as
extended under section 6081, for the return.

* * * * *

Par. 7. In the list below, for each section indicated in the left
column, remove the language in the middle column and add the
language in the right column. Affected Section Remove Add

1.1293-1(c)(1), last �1.1295-1T(j). �1.1295-1(j). sentence

1.1293-1(c)(2)(i), first �1.1295-1T(D)(2), �1.1295-1(d)(2), sentence

1.1295-1(b)(3)(iv)(A) stock), and stock) and

1.1295-1(c)(2)(ii), first 1296(a) 1297(a) sentence

1.1295-1(c)(2)(ii), first 1297(b)(1). 1298(b)(1). sentence

1.1295-1(c)(2)(iv), last �1.1293-1T(c). �1.1293-1(c). sentence

1.1295-1(d)(1), last (d)(5) (d)(6) sentence

1.1295-1(d)(2)(i)(A), last �1.1293-1T(c)(1), �1.1293-1(c)(1),
sentence

1.1295-1(d)(2)(ii), last �1.1293-1T(c)(1), �1.1293-1(c)(1), sentence

1.1295-1(d)(2)(iii), last �1.1293-1T(c)(1), �1.1293-1(c)(1),
sentence

1.1295-1(d)(6), first �1.1291-1T(e), �1.1291-1(e), sentence

1.1295-1(f)(1)(iii), last QEF calculated the QEF's PFIC calculated
the sentence PFIC's

1.1295-1(g)(1) representation -- representations -- introductory
text, second sentence, last word

1.1295-1(g)(1)(ii)(A) �1.1293-1T(a)(2) �1.1293-1(a)(2)

1.1295-1(h), second �1.1295-1T �1.1295-1 sentence

1.1295-1(i)(1)(iii), last never was made. was never made. sentence

1.1295-1(i)(3)(iii) through 1297 through 1298

1.1295-3(a), first sentence �1.1295-1T(j), �1.1295-1(j),

1.1295-3(a), first sentence �1.1295-1T(e) �1.1295-1(e)

1.1295-3(b)(2) and 1297 and 1298

1.1295-3(c)(3) �1.1295-1T(d). �1.1295-1(d).

1.1295-3(c)(4)(i)(A), third assessment of taxes assessment of all
PFIC sentence related taxes

1.1295-3(c)(6)(i), last see �1.1295-1T(c)(2)(iii). see �1.1295-1(c)
(2)(iii). sentence

1.1295-3(d)(1), first section 1296(a) section 1297(a) sentence

1.1295-3(d)(1), second section 1296(a) section 1297(a) sentence

1.1295-3(f)(2)(i) PFIC and the availability PFIC and of the
introductory text, second availability sentence

1.1295-3(f)(4)(vi), first �1.1295-1T(d). �1.1295-1(d). sentence

1.1295-3(g)(3), first �1.1295-1T(d). �1.1295-1(d). sentence

PART 602- - OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT

Par. 8. The authority citation for part 602 continues to read as
follows: Authority: 26 U.S.C. 7805.

Par. 9. In � 602.101, paragraph (b) is amended by removing the
entries for ��1.1295-1T and 1.1295-3T and adding entries in
numerical order to the table to read as follows:

� 602.101 OMB Control numbers.

* * * * *

(b) * * *

CFR part or section where Current OMB identified and described
control No.

* * * * *

1.1295-1 . . . . . . . . . . . . . .1545 - 1555

1.1295-3 . . . . . . . . . . . . . .1545 - 1555

* * * * *

Robert E. Wenzel
Deputy Commissioner of Internal Revenue
Approved: 1/14/00
Jonathan Talisman
Acting Assistant Secretary of the Treasury

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