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Articles

Retroactive QEF Elections

IRS Issues New Framework for Retroactive QEF Elections Under Revenue Procedure 2026-10 This week, the IRS released Revenue Procedure 2026-10, providing long-awaited clarity for passive foreign investment company (“PFIC”) shareholders seeking private letter rulings (PLRs) to obtain retroactive qualified electing fund (“QEF”) elections. The guidance introduces a...

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