Section 1298(c)(1)- (3) provides three rules that apply to PFIC stock held by a pooled income fund (as defined in section 642(c)(5)) when the fund’s governing instrument allows no gain from a disposition of the PFIC stock to be allocated to fund income: property) to be treated as distributions received by the shareholder. Section 1298(b)(8) requires subpart F income inclusions under section 951(a)(1)(B) (earnings invested in U.S. Section 1298(b)(7) (the subject of this article) allows foreign corporations that are subject to the section 531 accumulated earnings tax and that own stock in 25-percent-owned domestic corporations to treat stock owned by the domestic corporation as a non-passive asset and related income inclusions as non-passive income.Section 1298(b)(6) requires a taxpayer who uses PFIC stock as security for a loan to be treated as having disposed of the stock.person and treated in the same manner as previously taxed income. person is attributed ownership of stock in a PFIC under section 1298(a) and requires disposition of the PFIC stock or distribution by the PFIC to be treated as a disposition by or distribution to the U.S. Section 1298(b)(5) applies when a U.S.Section 1298(b)(4) provides that separate classes of stock (or other interests) in a corporation are to be treated as interests in separate corporations.Section 1298(b)(3) provides that corporations changing businesses will not be treated as PFICs.Section 1298(b)(2) provides that corporations will not be treated as PFIC’s during their start-up years. Section 1298(b)(1) provides that a stock ownership attribution determination is made at any time during the taxpayer’s holding period when the tested foreign corporation was a PFIC (and not a QEF).Section 1298(b)(1)- (8) (called “other special rules”) contains eight rules of varying complexity that address a wide variety of subjects:
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