SECTION 3. APPLICATION

As an alternative to applying the general rules under section 905(c), a RIC and its shareholders may discharge their obligations under sections 853 and 905(c) with respect to foreign tax refunds described below by utilizing either the method described in section 4 or the method described in section 5. Failure to discharge those obligations under either the general rules provided in section 905(c) or one of the alternative methods described in sections 4 and 5 may result in asserted deficiencies and penalties for the RIC and any shareholders of that RIC that claimed a related foreign tax credit.

February 8, 2016 308 Bulletin No. 2016–6