[Code of Federal Regulations] [Title 26, Volume 11] [Revised as of April 1, 2004] From the U.S. Government Printing Office via GPO Access [CITE: 26CFR1.1291-0] [Page 591] TITLE 26--INTERNAL REVENUE CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PART 1_INCOME TAXES--Table of Contents Sec. 1.1291-0 Treatment of shareholders of certain passive foreign investment companies; table of contents. This section contains a listing of the headings for Sec. Sec. 1.1291-9 and 1.1291-10. Sec. 1.1291-9 Deemed dividend election. (a) Deemed dividend election. (1) In general. (2) Post-1986 earnings and profits defined. (i) In general. (ii) Pro rata share of post-1986 earnings and profits attributable to shareholder's stock. (A) In general. (B) Reduction for previously taxed amounts. (b) Who may make the election. (c) Time for making the election. (d) Manner of making the election. (1) In general. (2) Attachment to Form 8621. (e) Qualification date. (1) In general. (2) Elections made after March 31, 1995, and before January 27, 1997. (i) In general. (ii) Exception. (3) Examples. (f) Adjustment to basis. (g) Treatment of holding period. (h) Coordination with section 959(e). (i) Election inapplicable to shareholder of former PFIC. (1) [Reserved] (2) Former PFIC. (j) Definitions. (1) Passive foreign investment company (PFIC). (2) Types of PFICs. (i) Qualified electing fund (QEF). (ii) Pedigreed QEF. (iii) Unpedigreed QEF. (iv) Former PFIC. (3) Shareholder. (k) Effective date. Sec. 1.1291-10 Deemed sale election. (a) Deemed sale election. (b) Who may make the election. (c) Time for making the election. (d) Manner of making the election. (e) Qualification date. (1) In general. (2) Elections made after March 31, 1995, and before January 27, 1997. (i) In general. (ii) Exception. (f) Adjustments to basis. (1) In general. (2) Adjustment to basis for section 1293 inclusion with respect to deemed sale election made after March 31, 1995, and before January 27, 1997. (g) Treatment of holding period. (h) Election inapplicable to shareholder of former PFIC. (i) Effective date. [T.D. 8701, 61 FR 68151, Dec. 27, 1996, as amended by T.D. 8750, 63 FR 13, Jan. 2, 1998] [[Page 592]]