SECTION 7. DRAFTING

INFORMATION

The principal authors of this revenue procedure are Alfred H. Bae and Jee Hyun Park of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Mr. Bae or Ms. Park at (202) 3176934 (not a toll-free call).

January 20, 2026 400 Bulletin No. 2026–4

APPENDIX CHECKLIST FOR RETROACTIVE QEF RULING REQUESTS

User Fees

A separate user fee for each PFIC for which the PFIC shareholder seeks consent to file a retroactive QEF election.

(a) General User Fee (Section 4.02(1)(a) of this revenue procedure, see also paragraph (A)(3)(c)(ii) of Appendix A to Rev. Proc.

2026-1) (b) Reduced User Fees (Section 4.02(1)(b) of this revenue procedure) (i) Substantially identical letter ruling requests ( see also paragraph (A)(5)(a) of Appendix A to Rev. Proc. 2026-1) (ii) Reduced user fees based on gross income ( see also paragraph (A)(4)(a) and (b) of Appendix A to Rev. Proc. 2026-1) (iii) Lowest available user fee ( see also Appendix A to Rev. Proc. 2026-1) A ruling request must include a statement indicating the relevant user fees with respect to each PFIC on the first page of the

submission, including, as applicable, a description of why the submission qualifies for reduced user fees.

Items to include with retroactive QEF election ruling submission

A statement listing the dates on which the PFIC shareholder acquired each interest in the PFIC and the PFIC shareholder’s own ership percentage of the PFIC after acquiring each interest (Section 4.02(2)(a) of this revenue procedure) PFIC Annual Information Statements (or Intermediary Statements or Combined Statements) (Section 4.02(2)(b) of this revenue

procedure) A detailed affidavit from the PFIC shareholder, or a person authorized to sign a Federal income tax return on behalf of the PFIC

shareholder, meeting the requirements of Treas. Reg. § 1.1295-3(f)(4)(ii) Detailed affidavits from other persons (as described in Section 4.02(2)(d) of this revenue procedure) A statement of facts and supporting documentation (as described in Section 4.02(2)(e) of this revenue procedure) A representation that the PFIC status of the corporation has not been raised on audit (Section 4.02(2)(f) of this revenue proce dure)

Bulletin No. 2026–4 401 January 20, 2026