IRS PLR: Retroactive QEF Elections Granted (I.R.C. §1295)

The IRS has published a private letter ruling on I.R.C. §1295 and Treas. Reg. §1.1295 granting consent for retroactive Qualified Electing Fund (QEF) elections for passive foreign investment companies where taxpayer reasonably relied on tax professional who failed to identify passive foreign investment companies or advise of QEF election availability. [PLR 202550006]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.