Tax treatment liquidating distribution pfic


26-Oct-2019 13:29

1029) added section 1411 to a new chapter 2A of subtitle A (Income Taxes) of the Code effective for taxable years beginning after December 31, 2012.

Section 1411 imposes a 3.8 percent tax on certain individuals, estates, and trusts.

Some comments responding to the 2012 Proposed Regulations requested that an election be provided.ACTION: Withdrawal of notice of proposed rulemaking and notice of proposed rulemaking.SUMMARY: This document contains proposed regulations under section 1411 of the Internal Revenue Code (Code).Treasury and the IRS are requesting comments with regard to whether or not taxpayers believe this election is preferable to the section 664 system adopted in the 2013 Final Regulations.

If it appears that there is no significant interest in having the election, the Treasury Department and the IRS may omit it from the regulations when finalized, and the simplified method contained in the 2012 Proposed Regulations would no longer be an option.ADDRESSES: Send submissions to: CC: PA: LPD: PR (REG-130843-13), room 5205, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington, DC 20044.



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