Form 8621 Return by a Shareholder of a Passive Foreign Investment

Form

8621

(Rev. December 2011)
Department of the Treasury
Internal Revenue Service
Name of shareholder

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

OMB No. 1545-1002
Attachment
Sequence No. 69

See separate instructions.
Identifying number (see instructions)

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

Shareholder tax year: calendar year 20
beginning

, 20

or other tax year

and ending

, 20

Nongrantor Trust

Estate

.

City or town, state, and ZIP code or country

Check type of shareholder filing the return:

Individual

Corporation

Partnership

S Corporation

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

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.
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.

D

Note: If any portion of line 1a or line 2a of Part II is includible under section 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.
Election To Recognize Gain on Deemed Sale of PFIC. I, a shareholder of a former PFIC or a PFIC to which section 1297(d) 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.
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.

E
F
G

Deemed Dividend Election With Respect to a Section 1297(e) PFIC. I, a shareholder of a section 1297(e) PFIC, within the meaning of
Regulations section 1.1291-9(j)(2)(v), elect to make a deemed dividend election with respect to the Section 1297(e) PFIC. My holding period in
the stock of the Section 1297(e) PFIC includes the CFC qualification date, as defined in Regulations section 1.1297-3(d).

H

Deemed Dividend Election With Respect to a Former PFIC. I, a shareholder of a former PFIC, within the meaning of Regulations section
1.1291-9(j)(2)(iv), elect to make a deemed dividend election with respect to the former PFIC. My holding period in the stock of the former PFIC
includes the termination date, as defined in Regulations section 1.1298-3(d).

Part II
1a
b
c
2a

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 instructions.)

Enter your pro rata share of the ordinary earnings of the QEF .

.

.

.

.

.

1a

Enter the portion of line 1a that is included in income under section 951 or that
1b
may be excluded under section 1293(g) . . . . . . . . . . . .
Subtract line 1b from line 1a. Enter this amount on your tax return as ordinary income .
Enter your pro rata share of the total net capital gain of the QEF . . . . .
2a

.

.

1c

b

Enter the portion of line 2a that is included in income under section 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.) . . . . . . . . . . . . .
Add lines 1c and 2c . . . . . . . . . . . . . . . . . . . . . . . . . .

.
.

2c

.
.

3d
3e

3a

.

.

.

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.) . .

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, or otherwise transferred during the tax year
.
3c
Add lines 3b and 3c . . . . . . . . . . . . . . . . . . . . . . .
Subtract line 3d from line 3a, and enter the difference (if zero or less, enter amount in brackets) .

4a
b

.

2b

b

d
e

.

3a

3b

.
.

.
.

.
.

Important: If line 3e is greater than zero, and no portion of line 1a or 2a is includible in income under section
951, you may make Election D with respect to the amount on line 3e.
4a
Enter the total tax for the tax year (See instructions.)
. . . . . . . .
Enter the total tax for the tax year determined without regard to the amount
entered on line 3e . . . . . . . . . . . . . . . . . .

.

4b

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 Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see separate instructions.
Cat. No. 64174H

4c
Form

8621 (Rev. 12-2011)

Form 8621 (Rev. 12-2011)

Part III
5a
b
c
6
7

Page

.
.

5a
5b

Subtract line 5b from line 5a. If a gain, do not complete lines 6 and 7. Include this amount as ordinary income
on your tax return. If a loss, go to line 6 . . . . . . . . . . . . . . . . . . . . .
Enter any unreversed inclusions (as defined in section 1296(d))
. . . . . . . . . . . . . .

5c
6

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 . . .

.
.

.
.

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.
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Enter the loss from line 5c, but only to the extent of unreversed inclusions on line 6. Include this amount as an
ordinary loss on your tax return . . . . . . . . . . . . . . . . . . . . . . . .
If you sold or otherwise disposed of any section 1296 stock (see instructions) during the tax year:
Enter the fair market value of the stock on the date of sale or disposition
. . . . . . . . . . .

8a

b

Enter the adjusted basis of the stock on the date of sale or disposition

.

8b

c

Subtract line 8b from line 8a. If a gain, do not complete line 9. Include this amount as ordinary income on your
tax return. If a loss, go to line 9 . . . . . . . . . . . . . . . . . . . . . . . .
Enter any unreversed inclusions (as defined in section 1296(d))
. . . . . . . . . . . . . .

8c
9a

b

Enter the loss from line 8c, but only to the extent of unreversed inclusions on line 9a. Include this amount as an
ordinary loss on your tax return. If the loss on line 8c exceeds unreversed inclusions on line 9a, complete line 9c

9b

c

Enter the amount by which the loss on line 8c exceeds unreversed inclusions on line 9a. Include this amount on
your tax return according to the rules generally applicable for losses provided elsewhere in the Code and
regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9c

8
a

9a

2

Gain or (Loss) From Mark-to-Market Election (See instructions.)

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7

Note. See instructions in case of multiple dispositions.

Part IV
10a

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

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 . .

.

10a

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) . . . . . . . . . . . . . . . . . . . . . . . . .

10b

c
d

Divide line 10b by 3. (See instructions if the number of preceding tax years is less than 3.)
Multiply line 10c by 125% (1.25)
. . . . . . . . . . . . . . . . .

.
.

10c
10d

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
. . . . . .

10e

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. . . . . . . . . . .

10f

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.

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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

11b

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.)
. . . . . . . . . . . . . . . .
Foreign tax credit. (See instructions.) . . . . . . . . . . . . . . . . . . . . . .
Subtract line 11d from line 11c. Enter this amount on your income tax return as “additional tax.” (See instructions.)

11c
11d
11e

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.)
. . . . . . . . . . . .

11f

d
e
f

Form

8621

(Rev. 12-2011)

Form 8621 (Rev. 12-2011)

Part V

Page 3

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
termination of the section 1294 election.
(i)

1

Tax year of outstanding
election . . . . . .

.

2

Undistributed earnings to
which the election relates
Deferred tax . . . .

.
.

3
4
5

(ii)

(iii)

(iv)

(v)

(vi)

Interest accrued on deferred
tax (line 3) as of the filing date
Event terminating election .

6

Earnings distributed or
deemed distributed during
the tax year
. . . . .

7

Deferred tax due with this
return . . . . . .

8

Accrued interest due with this
return . . . . . . .

9

Deferred tax outstanding after
partial termination of election .

10

Interest accrued after partial
termination of election . .

.

Form

8621

(Rev. 12-2011)