(a) In general. This section provides rules that apply to an individual, es-tate, or trust that is a United States shareholder of a controlled foreign cor-poration (CFC), or that is a United States person that directly or indi-rectly owns an interest in a passive for-eign investment company (PFIC). In addition, this section provides rules that apply to an individual, estate, or trust that owns an interest in a domes-tic partnership or an S corporation that is either a United States share-holder of a CFC or that has made an election under section 1295 to treat a PFIC as a qualified electing fund (QEF). References in this section to an election under paragraph (g) of this section being in effect relate to an election that is applicable to the per-son that is determining the section 1411 consequences with respect to holding a particular CFC or QEF.