u/Cakes2022

Election taken MTM in prior couple years. Need to update it to default election (1291) as marketability of investment is debatable. The PFIC is sellable and buyable from the corporation / provider to anyone all 365 days,. It is not traded on regular stock exchange, but available from the bank selling the ULIP policy. Policy holds mutual fund like investment underneath. Every CPA has their own interpretation. Planning to update the election to 1291 (excess dist) in 2025. Will it be allowed to change in prior with amendment ? 

for a MTM PFIC purchased in december of 2025. trying to figure what exchange rate to use for purchase price determination. Shall we use Dec 2025 (quarterly exchange rate - quarter in which. it was purchased ) or shall we use start of the year’s exchange rate ( Jan) if the delta is not too much does it matter ?

Also on the MTM PFIC, if the PFIC gives regular monthly interest income, regardless of whether it is final disposition year or not, Should the interest income be reported on sch B , or should it be reported on form 8621 by adjusting the cost price or the sale or 1/2 and 1/2 ? Or should the interest income be NOT reported on 8621 at all and should be reported on sch B. If it need not be reported on 8621, and there is a loss, how should that be handled for final disposition year?