PFIC: Revenue Procedure 2026-10 - Making A Retroactive Qualified Electing Fund (QEF) Election
Introduction The 1986 PFIC rules created a new tax regime for U.S. investors in certain foreign corporations. Generally, the rules should be understood to mean: If you do NOT pay tax before having received a distribution (1295 QEF Election usually resulting in @DoubleTaxation ) you will pay… pic.twitter.com/0l8IHKatV5 — John Richardson – Counsellor for US persons abroad (@ExpatriationLaw)…














