Hi all, had a situation I need some help with. PE fund owned interest in a bank that was a CFC that has 965 PTEP. Recently sold off part of it's interest and the bank is no longer considered a CFC. Under the new PFIC regs, I believe it qualifies as a PFIC. How would distributions be treated seeing as it would still qualify as a specified foreign corp?

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You’re asking if the PFIC rules apply or the CFC rules?

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