IRS Rev. Proc.: Procedures for Retroactive QEF Election Ruling Requests for PFIC Shareholders (IRC §1295)

The IRS published a revenue procedure establishing streamlined procedures for Passive Foreign Income Company (PFIC) shareholders to request private letter rulings, seeking consent to make retroactive qualified electing fund (QEF) elections, under I.R.C. §1295, when they failed to make timely elections due to reasonable reliance on qualified tax professionals who failed to identify foreign corporations as PFICs, or advise about election consequences. The guidance details required documentation, user fees, affidavit requirements, and procedures for demonstrating that granting relief would not prejudice U.S. government interests. [Rev Proc. 2026-10, 2026-4 I.R.B. (Jan. 20, 2026)]

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