Similar Posts


  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?


Comments are closed.

Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.