Examples of Deemed Sale in a sentence
Late Deemed Sale Election With Respect to a Former PFICEffect of ElectionPublicly traded corporations must use fair market value when determining PFIC statusThis is a deemed sale election under section 1298(b)(1) that is made with respect to ausing the asset test.A shareholder making this election is former PFIC after the time prescribed intreated as receiving a dividend of its pro rata Regulations section 1.1298-3(b)(3) hasWho May Make the ElectionLook-thru rule.
If the excess distribution is greater than zero, also complete line 16 of Part V.F Election To Recognize Gain on Deemed Sale of PFIC.
D Late Deemed Sale Election With Respect to a Section 1297(e) PFIC.
Because the proposed regulations apply a Deemed Sale by the passthrough entity of all its assets for cash equal to the fair market value of the entity’s properties, any gain or loss on the interest sale that is not reflected in the underlying properties of the passthrough entity (as the result of an inside-outside basis disparity) would not create an adjustment.
However, the Treasury Department and the IRS recognize that the Deemed Sale may impose an administrative burden on owners of partnerships and S corporations in certain circumstances.