SECTION 1. PURPOSE

.01 In General . This revenue procedure provides additional guidance on the process for requesting private letter rulings from the Internal Revenue Service (IRS), as generally set forth in Rev. Proc. 2026-1, 2026-1 I.R.B. 1, for consent to make retroactive qualified electing fund (QEF) elections under section 1295(b) of the Internal Revenue Code (Code) and Treas. Reg. § 1.1295-3(f).

Establishing whether a shareholder of a passive foreign investment company (PFIC) meets the requirements for making a retroactive QEF election and determining the correct user fee can be involved and fact intensive. In some cases, PFIC shareholders have submitted retroactive QEF election ruling requests that do not meet the requirements, contain incomplete information, are accompanied by incorrect user fees, or for which they are unable to provide additional information requested by the IRS that is necessary to determine whether the retroactive QEF election is available. These issues may prolong the ruling request process and increase the burden on both taxpayers and the IRS.

This revenue procedure is intended to improve the retroactive QEF election ruling process by explaining the require

ments for ruling eligibility, addressing common issues that arise with user fees in this context, and detailing the post-submission process, including the determination of whether granting consent would prejudice the interests of the United States government under Treas. Reg. § 1.12953(f)(3). .02 References . As the context requires, references to Rev. Proc. 2026-1 include successor revenue procedures.