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Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction

---
identifier: "/us/fr/06-682"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "06-682"
section_name: "Guidance on Passive Foreign Investment Company (PFIC) Purging Elections; Correction"
positive_law: false
currency: "2006-01-25"
last_updated: "2006-01-25"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "06-682"
document_type: "rule"
publication_date: "2006-01-25"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BD33"
fr_citation: "71 FR 4041"
fr_volume: 71
docket_ids:
  - "TD 9232"
effective_date: "2005-12-08"
fr_action: "Correcting amendment."
---

#  [Corrected]

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendment.

**SUMMARY:**

This document corrects temporary regulations (TD 9232) that were published in the *Federal Register* on Thursday, December 8, 2005 (70 FR 72908) that provide certain elections for taxpayers that continue to be subject to the PFIC excess distribution regime of  section 1291 even though the foreign corporation in which they own stock is no longer treated as a PFIC under section 1297(a) or (e).

**DATES:**

This correction is effective December 8, 2005.

**FOR FURTHER INFORMATION CONTACT:**

Ethan Atticks, (202) 622-3840 (not a toll-free number).

**SUPPLEMENTARY INFORMATION:**

**Background**

The temporary regulations are under sections 1291(d)(2), 1297(e) and 1298(b)(1) of the Internal Revenue Code.

**Need for Correction**

As published, the temporary regulations (TD 9232) contain errors that may prove to be misleading and are in need of clarification.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**26 CFR Part 1**

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendment:

**PART 1—INCOME TAXES**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *.

**26 CFR Part 1**

§ 1.1297-3T

1. Section 1.1297-3T(e)(1)(i), the language “December 31, 2005” is removed and the language “June 30, 2006” is added in its place.

**26 CFR Part 1**

2. Section 1.1298-3T(e)(1)(i), the language “December 31, 2005” is removed and the language “June 30, 2006” is added in its place.

Cynthia E. Grigsby,

Acting Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel, (Procedure and Administration).