Internal revenue. Part1:Income taxes (continued). Section1.1291-1T:Taxation of United States persons that are shareholders of section 1291 funds (temporary).
(a) through (b)(2)(i) [Reserved] (ii) Pedigreed QEF. A PFIC is a pedigreed QEF with respect to a shareholder if the PFIC has been a QEF with respect to the shareholder for all taxable years during which the corporation was a PFIC that are included wholly or partly in the shareholder's holding period of the PFIC stock.