[Federal Register Volume 64, Number 21 (Tuesday, February 2, 1999)]
[Proposed Rules]
[Page 5015]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 99-1665]


-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[INTL-941-86]
RIN 1545-AI33


Withdrawal of Guidance Under Section 1291 Relating to Mark to 
Market Elections for RICs

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Partial withdrawal of proposed regulations.

-----------------------------------------------------------------------

SUMMARY: This document withdraws Sec. 1.1291-8 of the notice of 
proposed rulemaking that was published in the Federal Register on April 
1, 1992, providing guidance under the passive foreign investment 
company (PFIC) rules relating to the mark to market election for 
regulated investment companies (RICs) that are shareholders of PFICs.

DATES: Section 1.1291-8 of the proposed regulations published at 57 FR 
11024 (April 1, 1992) is withdrawn February 2, 1999.

FOR FURTHER INFORMATION CONTACT: Robert Laudeman of the Office of 
Associate Chief Counsel (International), Internal Revenue Service, 1111 
Constitution Ave., NW., Washington, DC 20224. Telephone (202) 622-3840, 
not a toll-free number.

SUPPLEMENTARY INFORMATION:

Background

    On April 1, 1992 (57 FR 11024), the IRS issued proposed regulations 
providing, in part, an election under which certain RICs could mark to 
market their stock in certain PFICs. In the Taxpayer Relief Act of 1997 
Congress enacted section 1296(e)(2) of the Internal Revenue Code, which 
allows certain RICs to elect to mark to market their PFIC stock. 
Accordingly, the IRS is withdrawing proposed regulations Sec. 1.1291-8. 
Future guidance will be issued providing rules for all PFIC 
shareholders, including RICs, on how to mark to market certain PFIC 
stock.

Drafting Information

    The principal author of this withdrawal notice is Robert Laudeman, 
Office of the Associate Chief Counsel (International). However, other 
personnel from the IRS and Treasury Department participated in 
developing the withdrawal notice.

List of Subjects in Part 1

    Income taxes, Reporting and recordkeeping requirements.

Partial Withdrawal of Proposed Amendments to the Regulations

    Accordingly, under the authority of 26 U.S.C. 7805, Sec. 1.1291-8 
of the proposed amendments to 26 CFR part 1 published at 57 FR 11024, 
April 1, 1992, is withdrawn.
Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.
[FR Doc. 99-1665 Filed 2-1-99; 8:45 am]
BILLING CODE 4830-01-U