Schedule H 1040 Household Employment Taxes

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I.R.S. SPECIFICATIONS

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8621

(Rev. December 2004)

Date

Revised proofs
requested

Return by a Shareholder of a Passive Foreign
Investment Company or Qualified Electing Fund

Department of the Treasury
Internal Revenue Service

䊳

Signature

O.K. to print

PRINTS: HEAD to HEAD

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Form

Action

OMB No. 1545-1002
Attachment
Sequence No.

See separate instructions.

69

Name of shareholder

Identifying number (see page 2 of instructions)

Number, street, and room or suite no. (If a P.O. box, see page 2 of instructions.)

Shareholder tax year: calendar year 20
or other tax year
beginning
, 20
and ending
, 20

.

City or town, state, and ZIP code or country

Check type of shareholder filing the return:

Individual

Corporation

Partnership

S Corporation

Nongrantor Trust

Name of passive foreign investment company (PFIC) or qualified electing fund (QEF)

Employer identification number (if any)

Address (Enter number, street, city or town, and country.)

Tax year of company or fund: calendar year 20
tax year beginning
ending

Part I

or other

, 20
, 20

Estate

and

.

Elections (See instructions.)

A
B

Election To Treat the PFIC as a QEF. I, a shareholder of a PFIC, elect to treat the PFIC as a QEF. Complete lines 1a through 2c of Part II.
Deemed Sale Election. I, a shareholder on the first day of a PFIC’s first tax year as a QEF, elect to recognize gain on the
deemed sale of my interest in the PFIC. Enter gain or loss on line 10f of Part IV.

C

Deemed Dividend Election. I, a shareholder on the first day of a PFIC’s first tax year as a QEF that is a controlled foreign
corporation (CFC), elect to treat an amount equal to my share of the post-1986 earnings and profits of the CFC as an excess
distribution. Enter this amount on line 10e of Part IV.

D

Election To Extend Time For Payment of Tax. I, a shareholder of a QEF, elect to extend the time for payment of tax on
the undistributed earnings and profits of the QEF until this election is terminated. Complete lines 3a through 4c of Part II to
calculate the tax that may be deferred.
Note: If any portion of line 1a or line 2a of Part II is includible under section 551 or 951, you may not make this election.
Also, see sections 1294(c) and 1294(f) and the related regulations for events that terminate this election.

E

Election To Recognize Gain on Deemed Sale of PFIC. I, a shareholder of a former PFIC or a PFIC to which section 1297(e) applies, elect to
treat as an excess distribution the gain recognized on the deemed sale of my interest in the PFIC, or, if I qualify, my share of the PFIC’s post-1986
earnings and profits deemed distributed, on the last day of its last tax year as a PFIC under section 1297(a). Enter gain on line 10f of Part IV.

F

Election To Mark-to-Market PFIC Stock. I, a shareholder of a PFIC, elect to mark-to-market the PFIC stock that is
marketable within the meaning of section 1296(e). Complete Part III.

Part II

Income From a Qualified Electing Fund (QEF). All QEF shareholders complete lines 1a through 2c. If you are making
Election D, also complete lines 3a through 4c. (See page 5 of instructions.)

1a
1a Enter your pro rata share of the ordinary earnings of the QEF
b Enter the portion of line 1a that is included in income under
1b
section 551 or 951 or that may be excluded under section 1293(g)
c Subtract line 1b from line 1a. Enter this amount on your tax return as dividend income
2a
2a Enter your pro rata share of the total net capital gain of the QEF
b Enter the portion of line 2a that is included in income under
2b
section 551 or 951 or that may be excluded under section 1293(g)
c Subtract line 2b from line 2a. This amount is a net long-term capital gain. Enter this amount
in Part II of the Schedule D used for your income tax return. (See instructions.)
3a Add lines 1c and 2c
b Enter the total amount of cash and the fair market value of other
property distributed or deemed distributed to you during the tax
year of the QEF. (See instructions.)

2c
3a

3b

c Enter the portion of line 3a not already included in line 3b that is
attributable to shares in the QEF that you disposed of, pledged,
3c
or otherwise transferred during the tax year
d Add lines 3b and 3c
e Subtract line 3d from line 3a, and enter the difference (if zero or less, enter amount in brackets)
Important: If line 3e is greater than zero, and no portion of line 1a or 2a is includible in income
under section 551 or 951, you may make Election D with respect to the amount on line 3e.
4a
4a Enter the total tax for the tax year (See instructions.)
b Enter the total tax for the tax year determined without regard to
4b
the amount entered on line 3e
c Subtract line 4b from line 4a. This is the deferred tax, the time for payment of which is
extended by making Election D. See instructions
For Paperwork Reduction Act Notice, see page 7 of separate instructions.

1c

Cat. No. 64174H

3d
3e

4c
Form

8621

(Rev. 12-2004)

3
I.R.S. SPECIFICATIONS

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INSTRUCTIONS TO PRINTERS
FORM 8621, PAGE 2 of 2
MARGINS: TOP 13mm (1⁄2 "), CENTER SIDES.
PAPER: WHITE WRITING, SUB. 20. INK: BLACK
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279mm (11")
PERFORATE: (NONE)

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Page

Form 8621 (Rev. 12-2004)

Part III
5
6
7

Enter the fair market value of your PFIC stock at the end of the tax year
Enter your adjusted basis in the stock at the end of the tax year
Excess. Subtract line 6 from line 5. If a gain, stop here. Include this amount as ordinary income
on your tax return. If a loss, go to line 8
Enter any unreversed inclusions (as defined in section 1296(d)). See instructions.
Enter the smaller of line 7 or line 8. Include this amount as an ordinary loss on your tax return

8
9

Part IV

2

Gain or (Loss) From Mark-to-Market Election (See page 5 of instructions.)
5
6
7
8
9

Distributions From and Dispositions of Stock of a Section 1291 Fund (See page 6 of instructions.)
Complete a separate Part IV for each excess distribution (see instructions).

10a Enter your total distributions from the section 1291 fund during the current tax year with respect to the
applicable stock. If the holding period of the stock began in the current tax year, see instructions

b Enter the total distributions (reduced by the portions of such distributions that were excess
distributions but not included in income under section 1291(a)(1)(B)) made by the fund with
respect to the applicable stock for each of the 3 years preceding the current tax year (or if
shorter, the portion of the shareholder’s holding period before the current tax year)
c Divide line 10b by 3. (See instructions if the number of preceding tax years is less than 3.)
d Multiply line 10c by 125% (1.25)
e Subtract line 10d from line 10a. This amount, if more than zero, is the excess distribution with respect to
the applicable stock. If zero or less and you did not dispose of stock during the tax year, do not complete
the rest of Part IV. See instructions if you received more than one distribution during the current tax year.
Also, see instructions for rules for reporting a nonexcess distribution on your income tax return

f Enter gain or loss from the disposition of stock of a section 1291 fund or former section 1291
fund. If a gain, complete line 11. If a loss, show it in brackets and do not complete line 11
11a Attach a statement for each distribution and disposition. Show your holding period for each
share of stock or block of shares held. Allocate the excess distribution to each day in your
holding period. Add all amounts that are allocated to days in each tax year.
b Enter the total of the amounts determined in line 11a that are allocable to the current tax year
and tax years before the foreign corporation became a PFIC (pre-PFIC tax years). Enter these
amounts on your income tax return as other income
c Enter the aggregate increases in tax (before credits) for each tax year in your holding period
(other than the current tax year and pre-PFIC years). (See instructions.)
d Foreign tax credit. (See instructions.)
e Subtract line 11d from line 11c. Enter this amount on your income tax return as “additional
tax.” (See instructions.)
f Determine interest on each net increase in tax determined on line 11e using the rates and
methods of section 6621. Enter the aggregate amount of interest here. (See instructions.)

Part V

2

Deferred tax
Interest accrued on deferred
tax (line 3) as of the filing date

5
6

Event terminating election
Earnings distributed or deemed
distributed during the tax year
Deferred tax due with this
return
Accrued interest due with
this return
Deferred tax outstanding after
partial termination of election
Interest accrued after partial
termination of election

8
9
10

10e
10f

11b
11c
11d
11e
11f

(ii)

(iii)

(iv)

(v)

(vi)

Tax year of outstanding
election
Undistributed earnings to
which the election relates

3
4

7

10b
10c
10d

Status of Prior Year Section 1294 Elections and Termination of Section 1294 Elections
Complete a separate column for each outstanding election. Complete lines 9 and 10 only if there is a
partial ter mination of the section 1294 election.
(i)

1

10a

Form

8621

(Rev. 12-2004)

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Leading adjust: -20%
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Page 1 of 7

Instructions for Form 8621

9:12 - 22-NOV-2005

The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Instructions for Form 8621

Department of the Treasury
Internal Revenue Service

(Rev. December 2005)
(Use with the December 2004 revision of Form 8621.)
Return by a Shareholder of a Passive Foreign Investment Company or Qualified
Electing Fund
Section references are to the Internal Revenue Code unless otherwise noted.

General Instructions
Who Must File
Generally, a U.S. person that is a direct or
indirect shareholder of a PFIC must file
Form 8621 for each tax year in which that
U.S. person:
• Recognizes gain on a direct or indirect
disposition of PFIC stock,
• Receives certain direct or indirect
distributions from a PFIC, or
• Is making an election reportable in Part
I of the form.
A separate Form 8621 must be filed
for each PFIC in which stock is held. See
Chain of ownership below for specific
filing requirements.
Indirect shareholder. Generally, a U.S.
person is an indirect shareholder of a
PFIC if it is:
1. A direct or indirect owner of a
pass-through entity that is a direct or
indirect shareholder of a PFIC,
2. A shareholder of a PFIC that is a
shareholder of another PFIC, or
3. A 50%-or-more shareholder of a
foreign corporation that is not a PFIC and
that directly or indirectly owns stock of a
PFIC.
Interest holder of pass-through
entities. The following interest holders
must file Form 8621 under the
circumstances described above:
1. A U.S. person that is an interest
holder of a foreign pass-through entity
that is a direct or indirect shareholder of a
PFIC,
2. A U.S. person that is considered
(under sections 671 through 679) the
shareholder of PFIC stock held in trust,
and
3. A U.S. partnership, S corporation,
trust (other than a trust that is subject to
sections 671 through 679 for the PFIC
stock), or estate that is a direct or indirect
shareholder of a PFIC.
Note. U.S. persons that are interest
holders of pass-through entities described
in 3 above must file Form 8621 if the
pass-through entity fails to file such form
or the U.S. person is required to
recognize any income under either
section 1291 or section 1293.
Chain of ownership. If the shareholder
owns one PFIC and through that PFIC
owns one or more other PFICs, the
shareholder must either:

1. File a Form 8621 for each PFIC in
the chain or
2. Complete Form 8621 for the first
PFIC and, in an attachment, provide the
information required on Form 8621 for
each of the other PFICs in the chain.

When and Where To File
Attach Form 8621 to the shareholder’s tax
return and file both by the due date,
including extensions, of the return.
If you are not required to file an
income tax return or other return for the
tax year, file Form 8621 directly with the
Internal Revenue Service Center, P.O.
Box 21086, Philadelphia, PA 19114.

Definitions and Special
Rules
Passive Foreign Investment
Company (PFIC)
A foreign corporation is a PFIC if it meets
either the income or asset test described
below.
1. Income test. 75% or more of the
corporation’s gross income for its taxable
year is passive income (as defined in
section 1297(b)).
2. Asset test. At least 50% of the
average percentage of assets
(determined under section 1297(f)) held
by the foreign corporation during the
taxable year are assets that produce
passive income or that are held for the
production of passive income.
Basis for measuring assets. When
determining PFIC status using the asset
test, a foreign corporation may use
adjusted basis if:
1. The corporation is not publicly
traded for the taxable year and
2. The corporation is (a) a CFC or (b)
makes an election to use adjusted basis.
Publicly traded corporations must use
fair market value when determining PFIC
status using the asset test.
Look-thru rule. When determining if a
foreign corporation that owns at least
25% (by value) of another corporation is a
PFIC, the foreign corporation is treated as
if it held a proportionate share of the
assets and received directly its
proportionate share of the income of the
25%-or-more owned corporation.
CFC overlap rule. A 10% U.S.
shareholder (defined in section 951(b))
Cat. No. 10784P

that includes in income its pro rata share
of subpart F income for stock of a CFC
that is also a PFIC, generally will not be
subject to the PFIC provisions for the
same stock during the qualified portion of
the shareholder’s holding period of the
stock in the PFIC. This exception does
not apply to option holders. For more
information, see section 1297(e).
Note. The attribution rules of section
1298(a)(2)(B) will continue to apply even
if the foreign corporation is not a PFIC
under the CFC overlap rule.

Qualified Electing Fund (QEF)
A PFIC is a QEF if the U.S. person who is
a direct or indirect shareholder of the
PFIC elects (under section 1295) to treat
the PFIC as a QEF. See the instructions
for Election A on page 2 for information
on making this election.

Tax Consequences for
Shareholders of a QEF

• A shareholder of a QEF must annually
include in gross income as ordinary
income its pro rata share of the ordinary
earnings and as long-term capital gain the
net capital gain of the QEF.
• The shareholder may elect to extend
the time for payment of tax on its share of
the undistributed earnings of the QEF
(Election D) until the QEF election is
terminated.
• The shareholder may make a deemed
sale election (Election B) or a deemed
dividend election (Election C) to purge the
section 1291 fund years from its holding
period.
Note. A shareholder that receives a
distribution from an unpedigreed QEF
(defined in Regulations section
1.1291-9(j)(2)(iii)) is also subject to the
rules applicable to a shareholder of a
section 1291 fund (see page 2).
Basis adjustments. A shareholder’s
basis in the stock of a QEF is increased
by the earnings included in gross income
and decreased by a distribution from the
QEF to the extent of previously taxed
amounts.

Section 1291 Fund
A PFIC is a section 1291 fund if:
1. The shareholder did not elect to
treat the PFIC as a QEF or
2. It is an unpedigreed QEF (as
defined in Regulations section
1.1291-9(j)(2)(iii)).

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Instructions for Form 8621

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Tax Consequences for
Shareholders of a Section 1291
Fund
Shareholders of a section 1291 fund are
subject to special rules when they receive
an excess distribution (defined below)
from, or dispose of the stock of, a section
1291 fund. A distribution may be partly or
wholly an excess distribution. The entire
amount of gain from the disposition of a
section 1291 fund is treated as an excess
distribution.
Excess distributions. An excess
distribution is the part of the distribution
received from a section 1291 fund in the
current tax year that is greater than 125%
of the average distributions received in
respect to such stock by the shareholder
during the 3 preceding tax years (or, if
shorter, the portion of the shareholder’s
holding period before the current tax
year). No part of a distribution received or
deemed received during the first tax year
of the shareholder’s holding period of the
stock will be treated as an excess
distribution.
The excess distribution is determined
on a per share basis and is allocated to
each day in the shareholder’s holding
period of the stock. See section
1291(b)(3) for adjustments that are made
when determining if a distribution is an
excess distribution.
Portions of an excess distribution are
treated differently. The portions allocated
to the days in the current tax year and the
shareholder’s tax years in its holding
period before the foreign corporation
qualified as a PFIC (pre-PFIC years) are
taxed as ordinary income. The portions
allocated to the days in the shareholder’s
tax years (other than the current tax year)
in its holding period when the foreign
corporation was a PFIC are not included
in income, but are subject to the deferred
tax amount, as defined in section 1291(c).
See the instructions for Part IV on
page 5.
Exempt organizations. If a shareholder
of a PFIC is a tax exempt organization,
the tax and interest rules of section 1291
will apply only if the dividend from the
PFIC will be taxable to the shareholder
under subchapter F.

Mark-to-Market Election for
PFIC Stock
A U.S. shareholder of a PFIC may elect to
mark the PFIC stock to market if the stock
is “marketable stock.”
Marketable stock. Marketable stock is:
• PFIC stock that is regularly traded (as
defined in Regulations section
1.1296-2(b)) on:
1. A national securities exchange that
is registered with the Securities and
Exchange Commission (SEC),
2. The national market system
established under section 11A of the
Securities and Exchange Act of 1934, or
3. A foreign securities exchange that
is regulated or supervised by a
governmental authority of the country in
which the market is located and has the

characteristics described in Regulations
section 1.1296-2(c)(1)(ii).
• Stock in certain PFICs described in
Regulations section 1.1296-2.
• Any option on marketable stock
described above to the extent provided in
Regulations section 1.1296-2(e).
For additional information, including
special rules for RICs that own PFIC
stock, see Regulations section 1.1296-2.

shareholder has a P.O. box, enter the box
number instead.
Identifying number. Individuals should
enter a social security number or a
taxpayer identification number issued by
the IRS. All other entities should enter an
employer identification number.

Tax Consequences

A. Election To Treat the PFIC as
a QEF (Section 1295 Election)

If the PFIC shareholder elects to mark the
stock to market, the shareholder either:
1. Includes in income each year an
amount equal to the excess, if any, of the
fair market value of the PFIC stock as of
the close of the taxable year over the
shareholder’s adjusted basis in such
stock or
2. Is allowed a deduction equal to the
lesser of:
a. The excess, if any, of the adjusted
basis of the PFIC stock over its fair
market value as of the close of the tax
year or
b. The excess, if any, of the amount of
mark-to-market gain included in the gross
income of the PFIC shareholder for prior
taxable years over the amount allowed
such PFIC shareholder as a deduction for
a loss with respect to such stock for prior
taxable years.
See the instructions for Part III on
page 5 for more information.
Basis adjustment. If the stock is held
directly, the shareholder’s adjusted basis
in the PFIC stock is increased by the
amount included in income and
decreased by any deductions allowed. If
the stock is owned indirectly through
foreign entities, see Regulations section
1.1296-1(d)(2).

Additional Information
Required
A shareholder of a PFIC must attach
certain information to Form 8621. This
information includes:
• The number of shares in each class of
stock owned by the shareholder at the
beginning of its tax year;
• Any changes in the number of shares
in each class of stock during its tax year
and the dates of such changes; and
• The number of shares in each class of
stock at the end of its tax year.

Specific Instructions
Important: All line references to Form
1120 and Form 1040 are to the 2005
forms. Other entities should use the
comparable line on their tax return.

Address and Identifying
Number
Address. Include the suite, room, or
other unit number after the street
address. If the Post Office does not
deliver mail to the street address and the

-2-

Part I. Elections

Who May Make the Election
Generally, a U.S. person that owns stock
in a PFIC, directly or indirectly, may make
Election A to treat the PFIC as a QEF.
Note. A separate election must be made
for each PFIC that the shareholder wants
to treat as a QEF.
Exception. A tax-exempt organization
that is not taxable under section 1291
may not make the election. In addition, a
tax-exempt organization that is a member
of a domestic pass-through entity is not
subject to a QEF election made by the
pass-through entity.
Chain of ownership. In a chain of
ownership, only the first U.S. person that
is a direct or indirect shareholder of the
PFIC may make the election.
Pass-through entities. A QEF election
made by a domestic partnership, S
corporation, or estate is made in the
pass-through entity’s capacity as a
shareholder of a PFIC. The entity will
include the QEF earnings as income for
the year in which the PFIC’s taxable year
ends. The interest holder in the
pass-through entity takes the income into
account under the rules applicable to
inclusions of income from a pass-through
entity.
Affiliated groups. The common parent
of an affiliated group of corporations that
joins in filing a consolidated income tax
return makes the QEF election for all
members of the affiliated group that are
shareholders in the PFIC. An election by
a common parent is effective for all
members of the group that own stock in
the PFIC at the time the election is made
or any time thereafter.
For more information on who may
make the election, see Regulations
section 1.1295-1(d).

When To Make the Election
Generally, a shareholder must make the
election to be treated as a QEF by the
due date, including extensions, for filing
the shareholder’s income tax return for
the first taxable year to which the election
will apply (the “election due date”). See
Retroactive election on page 3 for
exceptions. The foreign corporation will
be treated as a QEF with respect to the
shareholder for the taxable year in which
the election is made and for each
subsequent tax year of the foreign
corporation ending with or within a
taxable year of the shareholder for which
the election is effective. For more
information on making a retroactive

Page 3 of 7

Instructions for Form 8621

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election, see Regulations section
1.1295-3.
Retroactive election. A shareholder
may make a QEF election for a taxable
year after the election due date (a
retroactive election), only if:
• The shareholder has preserved its right
to make a retroactive election under the
protective statement regime (described
below) or
• The shareholder obtains the permission
of the IRS to make a retroactive election
under the consent regime (described
below).
Protective statement regime. Under
the protective statement regime, a
shareholder may preserve the ability to
make a retroactive election if the
shareholder:
1. Reasonably believed, as of the due
date for making the QEF election, that the
foreign corporation was not a PFIC for its
taxable year that ended during that year
(retroactive election year);
2. Filed a Protective Statement (see
below) with respect to the foreign
corporation, applicable to the retroactive
election year, in which the shareholder
describes the basis for its reasonable
belief;
3. Extended, in the Protective
Statement, the periods of limitations on
the assessment of taxes under the PFIC
rules for all taxable years to which the
protective statement applies; and
4. Complied with the other terms and
conditions of the protective statements.
The Protective Statement must be
attached to the shareholder’s tax return
for the shareholder’s first taxable year to
which the statement will apply. For
required content of the statement and
other information, see Regulations
section 1.1295-3(c).
Consent regime. Under the consent
regime, a shareholder that has not
satisfied the requirements of the
protective regime may request that the
IRS permit a retroactive election. The
consent regime applies only if:
1. The shareholder reasonably relied
on tax advice of a competent and
qualified tax professional;
2. The interest of the U.S. government
will not be prejudiced if the consent is
granted;
3. The shareholder requests consent
before the PFIC status issue is raised on
audit; and
4. The shareholder satisfies the
procedural requirements under
Regulations section 1.1295-3(f)(4).

Special Rules
For rules relating to the invalidation,
termination, or revocation of a section
1295 election, see Regulations section
1295-1(i). Also see Regulations section
1.1295-1(c)(2) for rules relating to the
years to which a section 1295 election
applies.

How To Make the Election
For the tax year in which the section 1295
election is made, the shareholder must do
the following.
1. Check box A in Part I of Form
8621.
2. Complete the applicable lines of
Part II. Include the information provided in
the PFIC Annual Information Statement,
the Annual Intermediary Statement, or a
combined statement (see below) received
from the PFIC.
3. Attach Form 8621 to a timely filed
tax return.
For each subsequent tax year in which
the election applies and the corporation is
treated as a QEF, the shareholder must:
1. Complete the applicable lines of
Part II and
2. Attach Form 8621 to a timely filed
tax return.

Annual Election Requirements of
the PFIC or Intermediary
PFIC Annual Information Statement.
For each year of the PFIC ending in a
taxable year of a shareholder to which the
section 1295 election applies, the PFIC
must provide the shareholders with a
PFIC Annual Information Statement. The
statement must contain certain
information, including:
1. The shareholder’s pro rata share of
the PFIC’s ordinary earnings and net
capital gain for that taxable year or
2. Sufficient information to enable the
shareholder to calculate its pro rata share
of the PFIC’s ordinary earnings and net
capital gain for that taxable year. For
other information required to be included
in the PFIC Annual Information Statement
see Regulations section 1.1295-1(g).
Annual Intermediary Statement. If the
shareholder holds stock in a PFIC
through an intermediary, an Annual
Intermediary Statement may be issued in
lieu of the PFIC Annual Information
Statement. For the definition of an
intermediary, see Regulations section
1.1295-1(j). For details on the information
that should be included in the Annual
Intermediary Statement, see Regulations
section 1.1295-1(g)(3).
Combined statements. A PFIC that
owns directly or indirectly any shares of
stock in one or more PFICs may provide
its shareholders with a PFIC Annual
Information Statement in which it
combines its own required information
and representations with the information
and representations of any lower-tier
PFIC. Similarly, an intermediary through
which a shareholder indirectly holds stock
in more than one PFIC may provide the
shareholder a combined Annual
Intermediary Statement. For more
information, see Regulations section
1.1295-1(g)(4).
Documentation. For all taxable years
subject to the section 1295 election, the
shareholder must keep copies of all
Forms 8621, attachments, and all PFIC
Annual Information Statements or Annual

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Intermediary Statements. Failure to
produce these documents at the request
of the IRS may result in invalidation or
termination of the section 1295 election.
See Regulations section 1.1295-1(f)(2)(ii).
In rare and unusual circumstances, the
IRS will consider requests for alternative
documentation to verify the ordinary
earnings and net capital gain of the PFIC.
For more information, see Regulations
section 1.1295-1(g)(2).

B. Deemed Sale Election
Who May Make the Election
This election may be made by a U.S.
person that elects to treat a PFIC as a
QEF for a foreign corporation’s tax year
following its first tax year as a PFIC
included in the shareholder’s holding
period (an unpedigreed QEF). A
shareholder making this election is
deemed to have sold the PFIC stock as of
the first day of the PFIC’s first tax year as
a QEF (the qualification date) for its fair
market value.

Special Rules
For purposes of this election, the
following apply.
• The gain from the deemed sale is taxed
as an excess distribution received on the
qualification date.
• The basis of the stock is increased by
the gain recognized. The manner in which
the basis adjustment is made depends on
whether the shareholder is a direct or
indirect shareholder. See Regulations
section 1291-10(f).
• The new holding period of the stock
begins on the qualification date.
• The election may be made for stock on
which the shareholder will realize a loss,
but that loss cannot be recognized. In
addition, there is no basis adjustment for
a loss.
• After the deemed sale, the PFIC
becomes a pedigreed QEF with respect
to the shareholder.

When To Make the Election
This election must be made by the due
date, including extensions, of the
shareholder’s original tax return (or by
filing an amended return within 3 years of
the due date) for the tax year that
includes the qualification date.

How To Make the Election
To make this election:
1. Check box B in Part I,
2. Enter the gain or loss on line 10f of
Part IV, and
3. If a gain is entered, complete line
11 to report the tax and interest due on
the excess distribution.
For more information regarding
making Election B, see Regulations
section 1.1291-10.

C. Deemed Dividend Election
Who May Make the Election
This election may be made by a U.S.
person that elects to treat a PFIC that is
also a CFC as a QEF for the foreign
corporation’s tax year following its first tax

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year as a PFIC included in the
shareholder’s holding period (an
unpedigreed QEF).
A shareholder making this election is
treated as receiving a dividend of its pro
rata share of the post-1986 earnings and
profits (defined below) of the PFIC on the
qualification date (defined under the
instructions for Election B on page 3). The
deemed dividend is taxed as an excess
distribution, allocated only to the days in
the shareholder’s holding period during
which the foreign corporation qualified as
a PFIC. For this purpose, the
shareholder’s holding period ends on the
day before the qualification date.

• The provision of law under which the

amount was previously included in
income;
• A description of the transaction in
which the shareholder acquired the stock
of the PFIC from the other U.S. person;
and
• The provision of law under which the
shareholder’s holding period includes the
holding period of the other U.S. person.
For more information on making
Election C, see Regulations section
1.1291-9.

D. Election To Extend Time for
Payment of Tax

Special Rules

Who May Make the Election

For purposes of this election, the
following apply.
• The term “post-1986 earnings and
profits” means the undistributed earnings
and profits of the PFIC (as of the day
before the qualification date) accumulated
in tax years beginning after 1986 during
which the CFC was a PFIC and while the
shareholder held the stock.
• The basis of the shareholder’s stock is
increased by the amount of the deemed
dividend. The manner in which the basis
adjustment is made depends on whether
the shareholder is a direct or indirect
shareholder. See Regulations section
1.1291-9(f).
• The shareholder’s holding period
(solely for purposes of applying the PFIC
rules after the deemed dividend election)
begins on the qualification date.

A shareholder of a QEF may make
Election D to extend the time for payment
of the tax on its share of the undistributed
earnings of the fund for the current tax
year. If a U.S. partnership is a
shareholder of a QEF, the election is
made at the partner level.

When To Make the Election

When To Make the Election

This election must be made by the due
date (including extensions), of the
shareholder’s original tax return (or by
filing an amended return within 3 years of
the due date) for the tax year that
includes the qualification date.

Generally, this election must be made by
the due date, including extensions, of the
shareholder’s tax return for the tax year
for which the shareholder reports the
income related to the deferred tax.

How To Make the Election

To make this election:
1. Check box D in Part I and
2. Complete lines 3a through 4c of
Part II.

To make this election:
1. Check box C in Part I,
2. Enter the dividend on line 10e of
Part IV as an excess distribution, and
3. Complete line 11 to figure the tax
and interest due on the excess
distribution.
Attachments. The shareholder must
attach a statement to Form 8621 that
demonstrates the calculation of its pro
rata share of the post-1986 earnings and
profits of the PFIC that are treated as
distributed to the shareholder on the
qualification date. The post-1986 earnings
and profits may be reduced (but not
below zero) by the amount that the
shareholder satisfactorily demonstrates
was previously included in its income or in
the income of another U.S. person. The
shareholder demonstrates this by
including in the statement mentioned
above the following information:
• The name, address, and identifying
number of the U.S. person and the
amount that was included in income;
• The tax year in which the amount was
previously included in income;

Special Rules

• If this election is made, interest will be

imposed on the amount of the deferred
tax.
• The election cannot be made for any
earnings on shares disposed of during the
tax year or for a tax year that any portion
of the shareholder’s pro rata share of the
fund’s earnings is included in income
under section 551 (relating to foreign
personal holding companies) or section
951 (relating to CFCs).

How To Make the Election

For more information on making
Election D, see Temporary Regulations
section 1.1294-1T.

E. Election To Recognize Gain
on Deemed Sale of PFIC Stock
Who May Make the Election
This election may be made by:
• A U.S. person that is a shareholder of a
foreign corporation that no longer
qualifies as a PFIC under either the
income or asset test of section 1297(a) or
• A U.S. shareholder (as defined in
section 951(b)) that owns stock in a
foreign corporation that is a CFC and is
not treated as a PFIC with respect to the
U.S. shareholder under section 1297(e).
Such persons may elect to treat the
stock of the foreign corporation as sold on
the last day of the last tax year of the
foreign corporation in which it was treated
as a PFIC (termination date) for its fair
market value on that date.

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Special Rules

• The gain from the deemed sale is taxed
as an excess distribution.
• Any shareholder who owns stock in a
CFC during its last taxable year as a
PFIC, may, alternatively, apply the
deemed dividend election rules under
Election C. The deemed dividend is taxed
as an excess distribution.
• The basis in the stock is increased by
the amount of the excess distribution
taxed to the shareholder making
Election E.
• The new holding period of the stock
begins on the date after the deemed sale.
• Election E may be made for stock on
which there would be a loss, but the loss
is not recognized.
For more information on making this
election, see Temporary Regulations
sections 1.1297-3T(a) and (b).
When To Make the Election
This election is made either:
1. With the original return for the tax
year of the shareholder that includes the
last day of the last year of the foreign
corporation during which it qualified as a
PFIC or
2. By filing an amended return for the
tax year that includes the date of the
deemed sale.

How To Make the Election
To make this election:
1. Check box E in Part I and
2. Enter the gain or loss on line 10f of
Part IV. If a gain, complete the rest of Part
IV.
See Part V for annual reporting
requirements for outstanding section
1294 elections.

F. Election To Mark-to-Market
PFIC Stock
Who May Make the Election
Election F may be made by:

• A U.S. person who owns (or is treated

as owning) “marketable stock” (defined on
page 2) in a PFIC at the close of such
person’s tax year or
• A RIC that meets the requirements of
section 1296(e)(2).
For more information, see section
1296 and Regulations section 1.1296-1.
See sections 1296(f) and (g) and
Regulations sections 1.1296-1(e) and
(h)(1)(ii) for information regarding stock
owned through certain foreign entities.

When To Make the Election
This election must be made on or before
the due date (including extensions) of the
U.S. person’s income tax return for the
tax year in which the stock is marked to
market. A section 1296 election by a CFC
is made by its controlling shareholders.
For more information, see Regulations
section 1.1296-1(h)(1)(ii). Once made, the
election applies to all subsequent tax
years unless the election is revoked or
terminated pursuant to Regulations
section 1.1296-1(h)(3).

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How To Make the Election
To make the election:
1. Check box F in Part I,
2. Complete Part III to report the gain
or loss, and
3. Complete Part IV if the tax and
interest rules of section 1291 (explained
in the Part IV instructions, which begin
below) apply.
Coordination of Election F with section
1291. If Election F is made for any tax
year, then, except as provided in
Coordination rules for first year of election
below, do not complete Part IV of Form
8621 with respect to any stock for which
that election is made.
Coordination rules for first year of
election. See section 1296(j) and
Regulations section 1.1296-1(i) for
coordination rules that apply for the first
year that election F is made.
Coordination of other mark-to-market
rules under chapter 1 of the Code with
section 1291. See Regulations section
1.1291-1(c)(4).

Part II. Income From a QEF
For any tax year in which the foreign
corporation is not treated as a QEF
because it is not a PFIC under section
1297(a), the shareholder is not required
to complete Part II. However, the section
1295 election is not terminated. If the
foreign corporation is treated as a PFIC in
any subsequent tax year, the original
election continues to apply and the
shareholder must include in Part II its pro
rata share of ordinary earnings and net
capital gain and also must comply with
the section 1295 annual reporting
requirements.

Lines 1 and 2
Lines 1a and 2a. Enter on lines 1a and
2a, respectively, your pro rata share of
the ordinary earnings and net capital gain
of the QEF. The PFIC should provide
these amounts or information that will
help you determine your pro rata share.
See Annual Election Requirements of the
PFIC or Intermediary on page 3.
Lines 1b and 2b. Your share of the
ordinary earnings and net capital gain of
the QEF is reduced by the amounts you
include in income under section 551 or
951 for the tax year with respect to the
QEF. Your share of these amounts may
also be reduced as provided in section
1293(g).
Line 1c. This amount is treated as an
ordinary dividend on your tax return.
For individuals, include this amount in
the total on Form 1040, line 9a. For
corporations, include this amount in the
total on Form 1120, Schedule C, line 13.
Line 2c. See the instructions for the
Schedule D used for your tax return.
Portions of the net capital gain may have
to be reported on different lines of
Schedule D, depending upon the
information provided by the QEF

concerning the section 1(h) categories of
net capital gains and amounts thereof,
derived by the QEF. See Regulations
section 1.1293-1(a)(2) for 3 options a
QEF may use to report and calculate
capital gain.

Line 3
If you receive a distribution from the QEF
during the current tax year, the
distribution is first treated as a distribution
out of the earnings and profits of the QEF
accumulated during the year. If the total
amount distributed (line 3b) exceeds the
amount included in income (line 3a), the
excess is treated as distributed out of the
most recently accumulated earnings and
profits and is taxable to you unless you
satisfactorily demonstrate that the excess
was previously included in the income of
another U.S. person. To satisfactorily
demonstrate this, the QEF shareholder
must attach a statement to Form 8621
that includes the information listed under
Attachments on page 4.

Line 4
Line 4a. Enter the total tax on your total
taxable income (including your share of
undistributed earnings of the QEF) for the
tax year (e.g., from Form 1120, Schedule
J, line 11, or Form 1040, line 63).
For this purpose, “undistributed
earnings” is the excess, if any, of the
amount included in gross income under
section 1293(a) over the sum of the
amount of any distribution and the portion
of the amount attributable to stock in the
QEF that you transferred or otherwise
disposed of before the end of the QEF’s
tax year.
Line 4b. Calculate your total tax as if
your total taxable income did not include
your share of the undistributed earnings
of the QEF (line 3e). Enter this amount on
line 4b.
Line 4c. For corporations, enter this tax
on Form 1120, Schedule J, in brackets to
the left of the entry space for line 11.
Subtract that amount from the total of
lines 8 through 10 and enter the
difference on line 11.
For individuals, enter this tax on Form
1040 in brackets to the left of the entry
space for line 63. Subtract that amount
from the total of lines 57 through 62, and
enter the difference on line 63.

Part III. Gain or (Loss)
From Mark-to-Market
Election
Lines 7 Through 9
If the fair market value of the PFIC stock
as of the close of the tax year is more
than the U.S. person’s adjusted basis in
the stock, the excess is a gain and is
treated as ordinary income.
If the adjusted basis of the stock is
more than the fair market value, the
excess is allowed as a deduction, but only
to the extent of the lesser of:

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1. The amount of the excess (line 7)
or
2. The excess of the amounts that
were included in income under the
mark-to-market rules for prior tax years
over the amounts allowed as a deduction
under the mark-to-market rules for prior
tax years (line 8). See section 1296(d)
and Regulations sections 1.1296-1(c)(3)
and (4).
This amount is treated as an ordinary
loss.
Line 9. Corporations and individuals
should include the gain or (loss) on the
“other income” line of their tax returns.
Other entities should include this amount
on the comparable line of their tax return.
If a CFC makes a mark-to-market
election with respect to a PFIC in which it
owns stock, any line 9 gain is treated as
foreign personal holding company income
and any line 9 loss is treated as a
deduction that is allocable to foreign
personal holding company income.
For more information relating to
mark-to-market elections under section
1296, see Regulations sections 1.1296-1
and 1.1296-2.

Part IV. Distributions From
and Dispositions of Stock
of a Section 1291 Fund
See Section 1291 Fund on page 1 for the
definition of section 1291 fund. See page
2 for a brief summary of the tax
consequences for shareholders of a
section 1291 fund.
Complete a separate Part IV for each
excess distribution. That is, if you receive
a distribution from a section 1291 fund
with respect to shares for which you have
different holding periods, complete lines
10a through 10e separately for each
block of shares that has the same holding
period (“applicable stock”). If you dispose
of stock in a section 1291 fund for which
you have different holding periods,
complete line 10f for each block of shares
that has the same holding period.

Line 10
Lines 10a and 10b
Enter your total distributions from the
section 1291 fund with respect to the
applicable stock for the periods indicated.
Note. A distribution to a corporation
claiming the foreign tax credit for deemed
paid foreign taxes includes foreign taxes
deemed paid. See Form 1118, Foreign
Tax Credits – Corporations, Schedule C,
Part I, column 10, and Parts II and III,
column 8, for the gross-up amount.
Line 10a. If the holding period of the
applicable stock began in the current
year, there is no excess distribution and
Part IV should be completed as follows:
Enter on line 10a the total distributions
you received from the section 1291 fund
with respect to that stock during the
current tax year. If you did not dispose of
that stock during the tax year, do not

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complete the rest of Part IV. If you did
dispose of that stock during the tax year,
skip lines 10b through 10e and complete
lines 10f and 11.
If the holding period of the applicable
stock began in the current tax year, the
line 10a amount is taxed according to the
rules of section 301. To the extent that
section 301(c)(1) is applicable, include
the amount as a dividend on your income
tax return. For corporations, include this
amount on Form 1120, Schedule C, line
13. For individuals, include this line 10a
amount on Form 1040, line 9a (and, if
applicable, on Schedule B (Form 1040),
line 5).

Line 10c
Divide the amount on line 10b by 3. If the
number of tax years in your holding
period preceding the current tax year is
less than 3, divide the amount on line 10b
by that number.

Line 10e
Nonexcess distribution. The
nonexcess distribution is the lesser of line
10a or line 10d. This amount is taxed
according to the rules of section 301. To
the extent that section 301(c)(1) is
applicable, include the amount as a
dividend on your income tax return. For
corporations, include this amount on
Form 1120, Schedule C, line 13. For
individuals, include this amount on Form
1040, line 9a (and, if applicable, on
Schedule B (Form 1040), line 5).
Excess distributions. If you received
more than one distribution during the tax
year with respect to the applicable stock,
the excess distribution is apportioned
among all actual distributions. Each
apportioned amount is treated as a
separate excess distribution.

Line 10f
Gain recognized on the disposition of
stock of a section 1291 fund is treated as
an excess distribution. Losses are not
recognized. Stock of a section 1291 fund
is considered disposed of if it is sold,
transferred, or pledged.

Line 11
Lines 11a and 11b
Determine the taxation of the excess
distribution on a separate sheet and
attach it to Form 8621. Divide the amount
on line 10e or 10f, whichever applies, by
the number of days in your holding
period. The holding period of the stock is
treated as ending on the date of the
distribution or disposition.
Special rules apply to the holding
period if:
• The deemed dividend election (Election
C) is made (see the instructions for
Election C beginning on page 3) or
• The mark-to-market election (Election
F) is made or was made in a prior year
(see section 1291(a)(3)(A)(ii)).
Determine the amount allocable to
each tax year in your holding period by
adding the amounts allocated to the days
in each such tax year. Add the amounts

allocated to the pre-PFIC and current tax
years. Enter the sum on line 11b.
This amount is treated as ordinary
income (e.g., individuals and corporations
should enter this amount on the “other
income” line of their tax return).

Line 11c
Determine the increase in tax for each tax
year in your holding period (other than the
current tax year and pre-PFIC years). An
increase in tax is determined for each
PFIC year by multiplying the part of the
excess distribution allocated to each year
(as determined on line 11a) by the
highest rate of tax under section 1 or
section 11, whichever applies, in effect for
that tax year. Add the increases in tax
computed for all years. Enter the
aggregate increases in tax (before
credits) on line 11c.

Line 11d
To figure the foreign tax credit, the
shareholder of a section 1291 fund
figures the total creditable foreign taxes
attributable to the distribution. This
amount includes the direct foreign taxes
paid by the shareholder on the distribution
(for example, withholding taxes) and, for
10% or greater corporate shareholders,
any taxes deemed paid under section
902. Both the direct and indirect foreign
taxes must be creditable under general
foreign tax credit principles and the
shareholder must choose to claim the
foreign tax credit for the current tax year.
The excess distribution taxes (the
creditable foreign taxes attributable to an
excess distribution) are determined by
apportioning the total creditable foreign
taxes between the part of the distribution
that is an excess distribution and the part
that is not.
The excess distribution taxes are
allocated in the same manner as the
excess distribution is allocated. See
Excess distributions on page 2. Those
taxes allocated to pre-PFIC tax years and
the current tax year are taken into
account for the current tax year under the
general rules of the foreign tax credit.
The excess distribution taxes allocated
to a PFIC year only reduce the increase
in tax figured for that tax year (but not
below zero). No carryover of any unused
excess distribution taxes is allowed.
When you dispose of PFIC stock, the
above foreign tax credit rules apply only
to the part of the gain that, without regard
to section 1291, would be treated under
section 1248 as a dividend.

Line 11e
This amount is the aggregate increase in
tax and is included on your tax return as
additional taxes.
For individuals, enter this amount on
Form 1040 to the left of the line 44 entry
space. Enter “Sec. 1291” next to the
amount and include the amount as part of
the total for line 44.
For corporations, enter this amount on
Form 1120, Schedule J, to the left of the
entry space for line 3. Enter “Sec. 1291”

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next to the amount and include it as part
of the total for line 3. Other entities should
use the comparable line on their income
tax return.

Line 11f
Interest is charged on each net increase
in tax for the period beginning on the due
date (without regard to extensions) of
your income tax return for the tax year to
which an increase in tax is attributable
and ending with the due date (without
regard to extensions) of your income tax
return for the tax year of the excess
distribution.
For individuals, enter the interest at the
bottom right margin of Form 1040, page 1
and label it as “Sec. 1291 interest.”
Include this amount in your check or
money order payable to the United States
Treasury. If you would otherwise receive
a refund, reduce the refund by the interest
due.
For corporations, enter this interest at
the bottom right margin of Form 1120,
page 1, and label it as “Sec. 1291
interest.” Include this amount in your
check or money order payable to the
United States Treasury. If you would
otherwise receive a refund, reduce the
refund by the interest due.

Part V. Status of Prior Year
Section 1294 Elections and
Termination of Section
1294 Elections
Each person who has made a section
1294 election must (1) annually report the
status of that election and (2) report the
termination of any section 1294 election
that occurred during the tax year. See
Temporary Regulations section
1.1294-1T(h).
Line 1. Enter the last day of each tax
year for which you made a section 1294
election that is outstanding. Do not
include an election made in the current
tax year.
Line 2. Enter the undistributed earnings
of the QEF for which the payment of tax
was extended by the section 1294
election entered on line 1. If the election
was partially terminated in a prior year,
enter the remaining undistributed
earnings.
Line 3. Enter the tax for which payment
was extended by the section 1294
election entered on line 1. If the election
was partially terminated in a previous tax
year, enter the balance of the deferred
tax.
Line 4. Enter the accrued interest
(determined under section 6621) on the
deferred tax. This is the interest accrued
from the due date (not including
extensions) of the return for the year for
which the section 1294 election was
made until the date the current year’s
return is filed.
Line 5. Enter the event(s) that occurred
during the tax year that terminated one or

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more of the section 1294 elections
reported on line 1. A section 1294
election may be terminated voluntarily.
However, an election will terminate
automatically, in whole or in part, when
any of the following events occur:
• An actual or deemed distribution of
earnings to which the election is
attributable (a loan, pledge, or guarantee
by the QEF to or for the benefit of the
taxpayer may cause a deemed
distribution of the earnings);
• A disposition of stock in the QEF,
including a pledge by the taxpayer of
stock as security for a loan; or
• A change of status of the QEF (that is,
a foreign corporation that is no longer a
QEF or PFIC).
Line 6. Enter the earnings distributed or
deemed distributed as a result of the
events described on line 5. Earnings are
treated as distributed out of the most
recently accumulated earnings and
profits. Accordingly, an event will first
terminate the most recently made
election.
An election may be terminated in
whole or in part depending on the event
causing the termination. Examples are as
follows.
• A distribution of earnings will terminate
an election to the extent the election is
attributable to the earnings distributed.
• A loan, pledge, or guarantee by the
QEF made directly or indirectly to the
electing shareholder or related person will
terminate an election to the extent of the
undistributed earnings equal to the
amount loaned, secured, or guaranteed.
• A disposition of stock will terminate all
elections with respect to the undistributed
earnings attributable to that stock.
• A change in status of the QEF will
terminate all elections.
For more information, see Regulations
section 1.1294-1T(e).
Line 7. Enter the deferred tax due from
the termination of the section 1294
election. The deferred tax entered on line
3 is due if the election was completely
terminated. If the election was only
partially terminated, a proportionate
amount of the deferred tax is due. That
amount is determined by multiplying the
amount entered on line 3 by a fraction, of
which the numerator is the amount
entered on line 6 and the denominator is
the amount entered on line 2. The
deferred tax is due by the due date of the
shareholder’s income tax return (without
regard to extensions) for the year of
termination.
When the election is terminated,
corporations include the deferred tax as

part of the total for Form 1120, Schedule
J, line 11. Also enter the deferred tax to
the left of line 11 and label it as “Sec.
1294 deferred tax.”
For individuals, enter the deferred tax
as part of the total for Form 1040, line 63.
Also enter the deferred tax to the left of
line 63, and label it as “Sec. 1294
deferred tax.”
Line 8. Enter the interest accrued on the
deferred tax. Interest accrues beginning
on the due date (without regard to
extensions) of your tax return for the tax
year in which the section 1294 election is
made, and ending with the due date
(without regard to extensions) of your tax
return for the tax year of the termination.
Interest is computed using the rates and
methods under section 6621.
For corporations, enter the amount of
section 1294 interest at the bottom right
margin of Form 1120, page 1 and label it
as “Sec. 1294 interest.” Also include this
amount in your check or money order
payable to the United States Treasury. If
you would otherwise receive a refund,
reduce the refund by the interest due.
For individuals, enter the interest from
line 8 at the bottom right margin of Form
1040, page 1, and label it as “Sec. 1294
interest.” Also include this amount in your
check or money order payable to the
United States Treasury. If you would
otherwise receive a refund, reduce the
amount of the refund by the amount of
interest due.
Lines 9 and 10. Complete lines 9 and 10
only if you have partially terminated your
section 1294 election. Enter on line 9 the
part of the deferred tax outstanding after
the partial termination of the section 1294
election. This amount should equal line 3
minus line 7.
Enter on line 10 the accrued interest
remaining after the partial termination of
the section 1294 election. This amount
should equal line 4 minus line 8.

process your return and other papers.
You must fill in all parts of the tax form
that apply to you. If you do not file a
return under circumstances requiring its
filing, do not provide the information we
ask for, or provide fraudulent information,
you may be charged penalties and be
subject to criminal prosecution.
Generally, tax returns and return
information are confidential, as required
by section 6103. However, section 6103
allows or requires the Internal Revenue
Service to disclose or give the information
shown on your tax return to others as
described in the Code. For example, we
may disclose your tax information to the
Department of Justice for civil and
criminal litigation. We may also disclose
this information to cities, states, and the
District of Columbia for use in
administering their tax laws, to federal
and state agencies to enforce federal
nontax criminal laws, or to federal law
enforcement and intelligence agencies to
combat terrorism.
You are not required to provide the
information requested on a form that is
subject to the Paperwork Reduction Act
unless the form displays a valid OMB
control number. Books or records relating
to a form or its instructions must be
retained as long as their contents may
become material in the administration any
Internal Revenue law.
The time needed to complete and file
this form will vary depending on individual
circumstances. The estimated burden for
individual taxpayers filing this form is
approved under OMB control number
1545-0074 and is included in the
estimates shown in the instructions for
their individual income tax return. The
estimated burden for all other taxpayers
who file this form is shown below.

Disclosure, Privacy Act, and
Paperwork Reduction Act Notice. We
ask for the information on this form to
carry out the Internal Revenue laws of the
United States. Sections 6001, 6011,
6012(a), 6103, and 6109, and their
regulations, require you to provide this
information. We need this information to
ensure that you are complying with the
Internal Revenue laws and to allow us to
figure and determine the right amount of
tax.
Section 6109 requires that you provide
your identifying number on the return.
This is so we know who you are and can

Preparing and sending the
form to the IRS . . . . . . . . . . . 9 hr., 14 min.

-7-

Recordkeeping . . . . . . . . . . 13 hr., 37 min.
Learning about the law or the
form . . . . . . . . . . . . . . . . . . 8 hr., 38 min.

If you have comments concerning the
accuracy of these time estimates or
suggestions for making this form simpler,
we would be happy to hear from you. You
can write to the Internal Revenue Service,
Tax Products Coordinating Committee,
SE:W:CAR:MP:T:T:SP, 1111 Constitution
Ave. NW, IR-6406, Washington, DC
20224. Do not send the tax form to this
office. Instead, see When and Where To
File on page 1.