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2 Comments

  1. Hi Martha, to make the MTM election you must have “marketable stock”, which is defined under IRC §1296(e). There are a couple possible ways under that subsection that your stock can qualify as marketable stock; being regularly traded on a public exchange is one of them. See IRC §1296(e) and Regs. §1.1296-2. Regs. §1.1296-2(d) gives the specifics on the other way that the PFIC stock can qualify as marketable stock.

  2. So in order to be able to elect the MTM for a foreign mutual fund the shares of the fund must be regularly traded in a public exchange? What if you have shares in a foreign mutual fund managed by a foreign bank which are not regularly traded?

    Thanks!
    Martha

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