Help Is Available If You Forgot to Make a QEF Election
- February 2, 2026
- Publications
Roberts & Holland attorneys Ellen Brody and Avi Leiner published a new analysis in the latest issue of The New York State Society of CPA’s TaxStringer, on Rev. Proc. 2026‑10, the Internal Revenue Service’s latest guidance on retroactive Qualified Elected Fund (QEF) elections for Passive Foreign Investment Companies (PFIC).
The procedure introduces a more structured framework for taxpayers seeking relief after missing a QEF election deadline. It also outlines when the IRS may grant consent and how multiple PFICs may be bundled to reduce user fees. Given the significant consequences of an untimely QEF election, this development is particularly relevant for taxpayers and advisors working with foreign investments.