Description of the Technical Corrections Act of 1988 (S. 2238) : Additional Technical Corrections And Certain Other Provisions : Scheduled for Markup By the Senate Committee On Finance On July 26, 1988 Jcx-18-88

Cover Description of the Technical Corrections Act of 1988 (S. 2238) : Additional Technical Corrections And Certain Other Provisions : Scheduled for Markup By the Senate Committee On Finance On July 26, 1988 Jcx-18-88
Description of the Technical Corrections Act of 1988 (S. 2238) : Additional Technical Corrections And Certain Other Provisions : Scheduled for Markup By the Senate Committee On Finance On July 26, 1988 Jcx-18-88
United States. Congress. Joint Committee On Taxation
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2. Coordination of PFIC and charitable lead trust rules . --The amendment would provide that if PFIC stock is held by a charitable lead trust (or other trust with respect to which a charitable deduction is allowable with respect to an interest (other than a remainder interest) in the trust), then under regulations the income from PFIC stock distributions and gains upon which deferred tax amounts are computed may be adjusted to take into account the charitable obligations of the trust.
3. Termin
...ation of election to defer tax payment . — In the case of a taxpayer who elects to defer the payment of an undistributed PFIC earnings tax liability with respect to the taxpayer's stock in a PFIC that is a qualified electing fund, the amendment would provide that under regulations the election may continue in effect in the event that the taxpayer disposes of the PFIC stock in certain nonrecognition transactions .
4. Coordination of PFIC and pooled income fund rules . — If the governing instrument of a pooled income fund allows no portion of any gain from a disposition of PFIC stock owned by the fund to be allocated to income beneficiaries of the fund, then under the amendment the fund would not be taxed on undistributed PFIC earnings under the rules governing PFICs that are qualified electing funds; and gains realized by the pooled income fund on the disposition of PFIC stock would not be subject to the interest charge rules applicable to PFICs that are not qualified electing funds.


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