SECTION 8. EFFECTIVE DATE

Regulations to be issued relating to the guidance set forth in this notice will be

uals who are shareholders of an FPHC are not qualified dividend income. Similarly, undistributed foreign personal holding company income that is treated as distributed to individual U.S. shareholders as a dividend is not qualified dividend income. Further, a dividend from a foreign corporation that is not an FPHC but was an FPHC in the preceding taxable year is not qualified dividend income.

.02 FPHCs that are also CFCs

A foreign corporation may be both an FPHC and a CFC. Because a foreign corporation that is both an FPHC and a CFC continues to be an FPHC, any dividends (both actual dividends and amounts treated as a dividend) received by an individual shareholder from that corporation are not qualified dividend income.