Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Flowchart - PFIC Mark-to-Market Elections

2015-08-20

Today we published a flowchart on our sister website, Tax-Charts.com, regarding the application of mark-to-market (“MTM”) elections for passive foreign investment companies (“PFICs”). A PDF of the PFIC MTM flowchart is included here.

We now have twelve free flowcharts at Tax-Charts.com:

  1. Section 83: Rev. Proc 93-27 Taxation of Profits Interest
  2. Section 302: Distribution in Redemption of Stock
  3. Section 351 Exchange: Transfer to Corporation Controlled by Transferor(s)
  4. Section 351(g): Nonqualified Preferred Stock
  5. Section 357: Assumption of Liabilities in Certain Exchanges
  6. Section 736: Payments to a Retiring Partner or a Deceased Partner's Successor in Interest
  7. Section 894: U.K. - U.S. Income Tax Treaty: Taxation of Pension Distributions
  8. Section 894: Limitation on Benefits: Mexico-U.S. Income Tax Treaty
  9. Section 1296: PFIC Mark-to-Market (“MTM”) Elections
  10. Section 1298(f) Annual PFIC Reporting Requirements
  11. Section 7701: Rev. Proc. 2009-41 - Relief for Late Entity Classification Elections
  12. Attorney-Client Privilege
Tags: 1291 PFICs, Charts - Flowcharts