Making a Mark-to-Market Election

If the PFIC stock is "marketable," a defined term that basically requires it to be traded on certain listed systems or marketable under other listed circumstances, the shareholder can make the “mark-to-market” election and may include in his or her income the excess of the fair market value of the stock over the adjusted basis. Alternatively, the taxpayer will be allowed a deduction which must be the lesser of: (a) any excess of the adjusted basis over the fair market value or; (b) the excess of the amount of gain included in his or her gross income for prior tax years over the amount allowed as a deduction for a loss in prior tax years.

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