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PFIC Mark-to-Market Election Charts & Videos

2017-01-10

Today we added 12 new situational charts to andrewmitchel.com dealing with mark-to-market elections for PFICs. We also uploaded 12 new videos to our YouTube channel that briefly discuss each of the new charts. The charts and videos include:

Gain from MTM Election in Year After Acquisition Is Included in Unreversed Inclusions
- Reg. 1.1296-1(a)(3)(iii), Ex. (Video)
MTM Election Made in First PFIC Year, Which Was After Acquisition Year
- Reg. 1.1296-1(c)(7), Ex. 1 (Video)
Gain Recognized in Year Ceased to be a PFIC Was Long-Term Capital Gain
- Reg. 1.1296-1(c)(7), Ex. 2 (Video)
Ordinary Loss On Sale of 1296 Stock Because Loss Did Not Exceed Unreversed Inclusions
- Reg. 1.1296-1(c)(7), Ex. 3 (Video)
Loss Recognized in Year Ceased to be a PFIC Was Long-Term Capital Loss
- Reg. 1.1296-1(c)(7), Ex. 4 (Video)
Ordinary & Capital Loss On Sale of 1296 Stock Because Loss Exceeded Unreversed Inclusions
- Reg. 1.1296-1(c)(7), Ex. 5 (Video)
MTM Election With Two Lots of Stock (1 Gain & 1 Loss)
- Reg. 1.1296-1(c)(7), Ex. 6 (Video)
U.S. Partner Makes MTM Election Owning PFIC Thru Foreign P'ship
- Reg. 1.1296-1(d)(2)(ii), Ex. (Video)
Pre-Residency PFIC Share Acquisition With a MTM Election in First Year of U.S. Residency
- Reg. 1.1296-1(d)(5)(ii), Ex. (Video)
QEF Election, Then MTM Election, Then Stock Ceases To Be Marketable
- Reg. 1.1296-1(h)(4), Ex. 1 (Video)
QEF Election, Then MTM Election, Then Stock Ceases To Be Marketable, Then Stock Becomes Marketable Again
- Reg. 1.1296-1(h)(4), Ex. 2 (Video)
Coordination Rule Between Code §1291 & MTM Election
- Reg. 1.1296-1(i)(4), Ex. 1 (Video)

International Tax Blog - New and Interesting International Tax Issues

PFIC Mark-to-Market Election Charts & Videos

Tags: 1291 PFICs, Charts - Situational Charts, Other - Videos

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