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If a shareholder makes a QEF election in the first tax year the corporation is a PFIC, the PFIC taint does not apply.
Foods vary in their susceptibility to agents that cause taints.
Misconception 3) Smoke can affect next year's crop, too: Numerous sources and studies confirm that smoke taint does not linger in the plant in a way that could affect the quality of future harvests.
It's almost impossible not to apply the cork taint analogy to the current barrel TCA flap.
Winemakers who did not separate phenolic precursors from the must or juice still can reduce smoke taint from their 2008 vintage.
Keeping that in mind, Richmond estimated that ten years ago, industry experts would probably have found 3 to 6% cork taint, compared to 2 to 3% today, with an error rate of 2% to 4%.
Segregation of rental real estate from trade or business activities was included in the proposed regulations to further the "per se" passive taint of rental real estate.
Once a corporation becomes a PFIC with respect to a shareholder, it will continue to be a PFIC with respect to that shareholder until either of two elections purges the PFIC taint (Sec.
A planning opportunity exists to time profit-sharing contributions in such a way that contributions can be made for even/plan year but avoid the "active participation" taint for participants even/ third year.
101{a}(2)(A} and (B} will remove the "transfer-for-value" taint from a prior transfer.