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<br>Holder commonly will realize capital get or decline for U.S. Any these types of get or loss commonly will be addressed as U.S. U.S. source, and, as these kinds of, a U.S. Holder, which include an person, are issue to a lower rate less than present law if these kinds of U.S. The deductibility of cash losses is topic to restrictions. A U.S. Holder’s initial tax basis in shares commonly will equivalent the value of these kinds of shares. Holder’s holding period for the normal shares. Certain elections may well be readily available that would final result in choice treatment plans (such as mark-to-industry treatment method) of the standard shares. A well timed election to deal with us as a qualified electing fund beneath the Internal Revenue Code would end result in an alternative remedy. The principles governing the procedure of overseas taxes imposed on a U.S. Holder has created a "deemed sale" election under the PFIC rules. 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