For further information about Morgan Stanley Investment Management, please visit .As far as I know, there is no special rule for treating losses from the sale of a PFIC. (NYSE: TKF) (the “Fund”) announced today that the net asset value per share of the Fund for purposes of calculating the final liquidating distribution to stockholders was $9.1469 as of December 22, 2017 (the “Effective Date”).The IRS has not adopted any regulations on this matter, but the proposed regulations are fairly clear: Liquidating distributions are treated dispositions of the PFIC shares, not distributions in respect of shares; and a series of liquidating distributions is treated as a series of dispositions on each liquidating distribution date. Thus, the first cash payment is treated as payment in exchange for the PFIC shares.
Because our investor lost money on the investment, I assume the payment is less than his adjusted basis in the PFIC shares. Likewise, the second cash payment is treated as payment in exchange for the PFIC shares.
– Jackie Cameron By Dawn Ridler* Whenever uncertainty increases, South Africans start looking at how liquid they are if they want to get up and go, and this is one of those times.