SECTION 3. INFORMAL PRE-FILING

CONSULTATIONS WITH THE OFFICE OF ASSOCIATE CHIEF COUNSEL (INTERNATIONAL)

In the interest of making the retroactive QEF election ruling request process more effective and efficient, the Office of Associate Chief Counsel (International) invites PFIC shareholders and their representatives to contact the Office of Associate Chief Counsel (International) for an informal consultation in connection with determining whether to file a request. The consultation may include procedural or substantive issues. Statements or representations made by the Office of Associate Chief Counsel (International) in an informal consultation are not binding on the IRS. The requirements set forth in section 10 of Rev. Proc. 2026-1 with respect to conferences and pre-submission conferences do not apply to informal consultations under section 3 of this revenue procedure. Inquiries and informal consultation requests may be sent to CC.INTL. RetroQEF.PLR@irscounsel.treas.gov or made to the Office of Associate Chief Counsel (International) by phone at (202) 317-6934 (not a toll-free call). Conferences and pre-submission conferences described in section 10 of Rev. Proc. 2026-1 remain available to PFIC shareholders.