Late Deemed Dividend or Deemed Sale Election by a Passive Foreign Investment Company

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

i8621-a--2024-12-00

Late Deemed Dividend or Deemed Sale Election by a Passive Foreign Investment Company

OMB: 1545-1002

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Instructions for Form 8621-A
(Rev. December 2024)

(Use with the December 2024 revision of Form 8621-A.)
Return by a Shareholder Making Certain Late Elections To End Treatment as a
Passive Foreign Investment Company
Section references are to the Internal Revenue Code unless
otherwise noted.

in Part II or Part III of the form and computes the tax and interest due
in Part IV of the form.

What’s New

If the election year (defined below) is a closed tax year, the
taxpayer must enter into a closing agreement (page 3 of the form) to
agree to eliminate any prejudice to the interests of the U.S.
government as a consequence of the taxpayer's inability to file an
amended return for the election year.

OMB number update. At the request of OMB, the OMB number
shown on page 1 of Form 8621-A has been revised. The new OMB
number is 1545-1002. Also, OMB has advised that the OMB
numbers (1545-0074 and 1545-0123) referred to in the Disclosure,
Privacy Act, and Paperwork Reduction Act Notice at the end of these
instructions remain the same.

Future Developments
For the latest information about developments related to Form
8621-A and its instructions, such as legislation enacted after they
were published, go to IRS.gov/Form8621A.

General Instructions
Purpose of Form

A U.S. person that is a direct or indirect shareholder of a former
Passive Foreign Investment Company (PFIC) or a Section 1297(e)
PFIC is treated for tax purposes as holding stock in a PFIC and
therefore continues to be subject to taxation under section 1291
unless the shareholder makes a purging election under section
1298(b)(1).

!

CAUTION

A separate Form 8621-A must be filed for each PFIC for which a
late purging election is being made. See Chain of ownership below
for specific filing requirements.
Chain of ownership. If the shareholder owns one PFIC and
through that PFIC owns one or more other PFICs, the shareholder
must file a separate Form 8621-A for each Section 1297(e) PFIC or
former PFIC in the chain for which a late purging election is made.
The shareholder files these Forms 8621-A together.

Where To File
File Form 8621-A with:

Internal Revenue Service
Deposit Team, M/S 6059
Attn: Specials Desk
Ogden, UT 84201

A purging election under section 1298(b)(1) is:

• A deemed dividend election or a deemed sale election made with

respect to a former PFIC under the rules of Regulations sections
1.1298-3(b) or 1.1298-3(c), or
• A deemed dividend election or a deemed sale election made with
respect to a Section 1297(e) PFIC under the rules of Regulations
sections 1.1297-3(b) or 1.1297-3(c).
A timely filed purging election is made on Form 8621.
Form 8621-A is used only to make a late purging election under
section 1298(b)(1). A late purging election is a purging election
under section 1298(b)(1) that is made:
• In the case of a shareholder of a former PFIC, after 3 years from
the due date, as extended, of the tax return for the tax year that
includes the termination date, or
• In the case of a shareholder of a section 1297(e) PFIC, after 3
years from the due date, as extended, of the tax return for the tax
year that includes the CFC qualification date.
See Regulations sections 1.1298-3(e) or 1.1297-3(e) for more
details.
Generally, the amount due with respect to a late purging election
is computed in the same manner as if the purging election had been
timely filed. However, the taxpayer must also pay interest on the
amount due determined for the period beginning on the due date
(without extensions) for the taxpayer's income tax return for the
election year and ending on the date the late purging election is filed
with the IRS. See the instructions for Part I, later, for details.

How To Complete Form 8621-A

The shareholder makes the applicable election in Part I of the form.
The shareholder then provides basic information about the election

Jan 3, 2025

The closing agreement must be filed in duplicate and both
copies must contain original signatures. See Closing
Agreement, later, for additional information.

Filing Checksheet

Be sure to:
• Check the applicable box in Part I of the form that corresponds to
the election you are making.
• Complete the applicable lines in Part II or III of the form (along
with any required attachments requested on any of those lines) as
requested at the end of the election description in Part I of the form.
• Complete Part IV of the form along with any required attachments
requested on any of the lines in Part IV.
• Sign and date the form in the spaces provided at the bottom of
page 2 of the form.
• If the election year is a closed tax year, file the closing agreement
on page 3 of the form in duplicate. Both copies must contain
original signatures. See Closing Agreement, later, for details.
• Complete the balance sheet on page 4 of the form, if applicable
(that is, if required by line 4 or line 8 of the form).
• Keep a copy of the form for your records.
• Make your check or money order payable to “United States
Treasury.” Include your identifying number and “Form 8621-A” on
your payment.

!

If Form 8621-A doesn't include full payment of the amount
shown on line 21 of the form, the form won’t be processed.

CAUTION

Definitions
Controlled Foreign Corporation (CFC)
See section 957(a) for definition.

Instructions for Form 8621A (Rev. 12-2024) Catalog Number 39731G
Department of the Treasury Internal Revenue Service www.irs.gov

CFC Overlap Rules
A 10% U.S. shareholder (defined in section 951(b)) of a CFC that is
also a PFIC that includes in income its pro rata share of subpart F
income of the CFC generally won’t 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 doesn’t apply
to option holders. For more information, see section 1297(d).
Qualified portion of holding period. For purposes of section
1297(d), the qualified portion of the shareholder's holding period in a
corporation is the portion of the shareholder's holding period:
• That is after December 31, 1997, and
• During which the shareholder is a U.S. shareholder under section
951(b) and the corporation is a CFC.
CFC qualification date. The CFC qualification date is the first day
on which the qualified portion of the shareholder's holding period in
the Section 1297(e) PFIC begins, as determined under section
1297(d).
Section 1297(e) PFIC. A foreign corporation is a Section 1297(e)
PFIC with respect to a shareholder if:
1. The foreign corporation qualifies as a PFIC under section
1297(a) on the first day on which the qualified portion of the
shareholder's holding period in the foreign corporation begins, as
determined under section 1297(d) (CFC overlap rule), and
2. The stock of the foreign corporation held by the shareholder
is treated as stock of a PFIC, under section 1298(b)(1), because, at
any time during the shareholder's holding period of the stock, other
than the qualified portion, the corporation was a PFIC that wasn’t a
QEF.

Election Year

2. Asset test. At least 50% of the average percentage of assets
(determined under section 1297(e)) held by the foreign corporation
during the tax 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 can use adjusted basis if:
1. The corporation isn’t publicly traded for the tax year and
2. The corporation (a) is 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.

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 Form 8621 for more
information.

Shareholder

A shareholder is a U.S. person that is a direct or indirect shareholder
of the foreign corporation. See Indirect shareholder, earlier, for
definition.

Termination Date

The termination date is the last day of the last tax year of the foreign
corporation during which it qualified as a PFIC under section
1297(a).

• In the case of a former PFIC, the election year is the tax year of
the electing shareholder that includes the termination date.
• In the case of a Section 1297(e) PFIC, the election year is the tax
year of the electing shareholder that includes the CFC qualification
date.

Specific Instructions

Former PFIC

Address and Identifying Number

A foreign corporation is a former PFIC with respect to the
shareholder if the corporation satisfies neither the income test nor
the asset test (described under the definition of PFIC below), but
whose stock, held by that shareholder, is treated as stock of a PFIC,
under section 1297(b)(1), because at any time during the
shareholder's holding period of the stock the corporation was a PFIC
(under the income or asset test of section 1297(a) described below)
that wasn’t a QEF, and the shareholder hasn’t made a
mark-to-market election with respect to the PFIC.

Indirect Shareholder

Generally, a U.S. person is an indirect shareholder of a Section
1297(e) PFIC or a former PFIC if it is:
1. A direct or indirect owner of a pass-through entity that is a
direct or indirect shareholder of a Section 1297(e) PFIC or a former
PFIC,
2. A shareholder of a PFIC that is a shareholder of a Section
1297(e) PFIC, or a former PFIC,
3. A 50%-or-more shareholder of a foreign corporation that isn’t
a PFIC and that directly or indirectly owns stock of a Section 1297(e)
PFIC or a former PFIC, or
4. A 50%-or-more shareholder of a domestic corporation that
owns a section 1291 fund.

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 tax year is passive income (as defined in section 1297(b)).
2

Address. Include the suite, room, or other unit number after the
street address. If the Post Office doesn’t deliver mail to the street
address and the shareholder has a P.O. box, enter the box number
instead.
Identifying number. Individuals should enter a social security
number or taxpayer identification number issued by the IRS. Entities
must enter an employer identification number.
Shareholder Contact Information. If the person to contact with
respect to Form 8621-A is the taxpayer, enter “Same” in the entry
space for the name. If the person to contact with respect to Form
8621-A is a person other than the taxpayer, enter the information
requested and attach Form 2848.

Part I. Elections
Election A. Late Deemed Dividend Election With
Respect to a Former PFIC

This is a deemed dividend election under section 1298(b)(1) that is
made with respect to a former PFIC after the time prescribed in
Regulations section 1.1298-3(c)(4) has elapsed.

Who Can Make the Election
This election can be made by a U.S. person that is a shareholder of
a foreign corporation that is a former PFIC with respect to such
shareholder provided the foreign corporation was a CFC during the
last tax year as a PFIC.

Instructions for Form 8621-A (Rev. 12-2024)

Effect of Election

Effect of Election

A shareholder making this election is treated as receiving a dividend
of its pro rata share of the post-1986 earnings and profits of the
former PFIC on the termination date. The deemed dividend is taxed
under section 1291 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 termination date. After the deemed
dividend election, the shareholder's stock isn’t treated as stock in a
PFIC unless the foreign corporation thereafter qualifies as a PFIC.

A shareholder making this election is deemed to have sold the
former PFIC stock on the termination date for its fair market value.
The gain from the deemed sale is taxed under section 1291 as an
excess distribution received on the termination date. After the
deemed sale election, the shareholder's stock isn’t treated as stock
in a PFIC unless the foreign corporation thereafter qualifies as a
PFIC.

Special Rules

For purposes of this election, the following apply.
• The basis of the shareholder's stock is increased by the gain
recognized on the deemed sale. The manner in which the basis
adjustment is made depends on whether the shareholder is a direct
or indirect shareholder. See Regulations section 1.1298-3(b)(5).
• For purposes of the PFIC rules only, the shareholder's new
holding period of the stock begins on the day following the
termination date.
• The election can 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.

For purposes of this election, the following apply.
• 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 1.1298-3(c)(6).
• For purposes of the PFIC rules only, the shareholder's new
holding period begins on the day following the termination date.
• The term “post-1986 earnings and profits” means the
undistributed earnings and profits of the PFIC (as of the close of the
tax year that includes the termination date without reduction for
dividends distributed during the tax year) accumulated in tax years
beginning after 1986 during which the CFC was a PFIC and while
the shareholder held the stock.

Line 3 Attachment
The shareholder must attach a statement to Form 8621-A that
shows the calculation of its pro rata share of the post-1986 earnings
and profits of the former PFIC that is treated as distributed to the
shareholder on the termination date. The post-1986 earnings and
profits can be reduced (but not below zero) by the amount that the
shareholder satisfactorily shows was previously included in its
income or in the income of another U.S. person. The shareholder
shows 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 previously included in income;
• The tax year in which the amount was previously included in
income;
• 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 former 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.

How To Make the Election
To make this election, check box A in Part I and complete Part II,
lines 1, 2, and 3, and Part IV.
For more information on making Election A, see Regulations
section 1.1298-3(c) and Regulations section 1.1298-3(e).

Election B. Late Deemed Sale Election With
Respect to a Former PFIC

This is a deemed sale election under section 1298(b)(1) that is
made with respect to a former PFIC after the time prescribed in
Regulations section 1.1298-3(b)(3) has elapsed.

Who Can Make the Election
This election can be made by a U.S. person that is a shareholder of
a former PFIC.

Instructions for Form 8621-A (Rev. 12-2024)

Special Rules

How To Make the Election
To make this election, check box B in Part I and complete Part II,
lines 1, 2, and 4, and Part IV.
For more information regarding making Election B, see
Regulations section 1.1298-3(b) and Regulations section
1.1298-3(e).

Election C. Late Deemed Dividend Election With
Respect to a Section 1297(e) PFIC
This is a deemed dividend election under section 1298(b)(1) that is
made by a shareholder (defined earlier) with respect to a Section
1297(e) PFIC that is also a CFC after the time prescribed in
Regulations section 1.1297-3(c)(4) has elapsed.

Who Can Make the Election
The election can be made by a shareholder of a foreign corporation
that is a Section 1297(e) PFIC with respect to that shareholder.

Effect of Election
A shareholder making this election is treated as receiving a dividend
of its pro rata share of the post-1986 earnings and profits of the
Section 1297(e) PFIC on the CFC qualification date. The deemed
dividend is taxed under section 1291 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 CFC
qualification date. After the deemed dividend election, the
shareholder's stock isn’t treated as stock in a PFIC unless the
qualified portion of the shareholder's holding period ends, and the
foreign corporation thereafter qualifies as a PFIC.

Special Rules
For the purpose of this election, the following apply:
• 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 1.1297-3(c)(6).
• For purposes of the PFIC rules only, the shareholder's new
holding period begins on the CFC qualification date.
• The term “post-1986 earnings and profits” means the
undistributed earnings and profits of the PFIC (as of the day before
3

the CFC qualification date) accumulated in tax years beginning after
1986 during which the CFC was a PFIC and while the shareholder
held the stock.

Line 7 Attachment
The shareholder must attach a statement to Form 8621-A that
shows the calculation of its pro rata share of the post-1986 earnings
and profits of the Section 1297(e) PFIC that is treated as distributed
to the shareholder on the CFC qualification date. The post-1986
earnings and profits can be reduced (but not below zero) by the
amount that the shareholder satisfactorily shows was previously
included in its income or in the income of another U.S. person. The
shareholder shows 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 previously included in income;
• The tax year in which the amount was previously included in
income;
• A description of the transaction in which the shareholder acquired
the stock of the Section 1297(e) 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.

How To Make the Election
To make this election, check box C in Part I and complete Part III,
lines 5, 6, and 7, and Part IV.
For more information on making Election C, see Regulations
sections 1.1297-3(c) and (e).

Election D. Late Deemed Sale Election With
Respect to a Section 1297(e) PFIC

This is a deemed sale election under section 1298(b)(1) that is
made with respect to a Section 1297(e) PFIC after the time
prescribed in Regulations section 1.1297-3(b)(3) has elapsed.

Who Can Make the Election
This election can be made by a U.S. person that is a shareholder of
a foreign corporation that is a section 1297(e) PFIC with respect to
such shareholder.

Effect of Election
A shareholder making this election is deemed to have sold the
Section 1297(e) PFIC stock on the CFC qualification date for its fair
market value. The gain from the deemed sale is taxed under section
1291 as an excess distribution received on the CFC qualification
date. After the deemed sale election, the shareholder's stock isn’t
treated as stock in a PFIC unless the qualified portion of the
shareholder's holding period ends, and the foreign corporation
thereafter qualifies as a PFIC.

How To Make the Election
To make this election, check box D in Part I and complete Part III,
lines 5, 6, and 8, and Part IV.
For more information on making Election D, see Regulations
sections 1.1297-3(b) and (e).

Part IV. Computation of Tax and
Interest Due
Line 9a

Enter the amount treated as an excess distribution under the
deemed dividend or deemed sale election. This amount is:
• In the case of a deemed dividend election for a former PFIC, the
amount on line 3 of Part II.
• In the case of a deemed sale election for a former PFIC, the
amount on line 4 of Part II.
• In the case of a deemed dividend election for a Section 1297(e)
PFIC, the amount on line 7 of Part III.
• In the case of a deemed sale election for a Section 1297(e) PFIC,
the amount on line 8 of Part III.

Lines 9b and 10

Determine the allocation of the excess distribution to all applicable
tax years on a separate sheet and attach it to Form 8621-A. Divide
the amount on line 9a by the number of days in your holding period.
The holding period of the stock is treated as ending on:
• The termination date, in the case of a deemed sale or deemed
dividend election for a former PFIC;
• The CFC qualification date, in the case of a deemed sale election
for a Section 1297(e) PFIC; and
• The day before the CFC qualification date, in the case of a
deemed dividend election for a Section 1297(e) PFIC.
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. Then:
• Add the amounts allocated to the tax years before the foreign
corporation became a PFIC (pre-PFIC years) and amounts allocated
to the election year. Enter the sum on line 10.
• With respect to the amounts allocated to each tax year in your
holding period other than the election year and the pre-PFIC years,
see the instructions for Line 14.

Lines 11 and 12

The shareholder's income tax liability is generally the amount shown
on the “total tax” line of the return.

Line 14

Special Rules

Determine the increase in tax for each tax year in your holding period
other than the election year and pre-PFIC years (that is, for each
PFIC year). An increase in tax is determined for each PFIC year by
multiplying the part of the distribution or disposition allocated to each
year (see Lines 9b and 10, earlier) 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 PFIC years. Enter the
aggregate increases in tax (before credits) on line 14.

For purposes of this election, the following apply.
• The basis of the shareholder's stock is increased by the gain
recognized on the deemed sale. The manner in which the basis
adjustment is made depends on whether the shareholder is a direct
or indirect shareholder. See Regulations section 1.1297-3(b)(5).
• For purposes of the PFIC rules only, the shareholder's new
holding period begins on the CFC qualification date.
• The election can 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.

To determine the foreign tax credit, the shareholder of a section
1291 fund determines the total creditable foreign taxes attributable
to the distribution. The total creditable foreign taxes with respect to
any distribution are the withholding taxes imposed on the distribution
and, in the case of a foreign corporation year beginning before
January 1, 2018, for 10% or greater corporate shareholders, any
taxes deemed paid under section 902. The 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.

4

Line 15

Instructions for Form 8621-A (Rev. 12-2024)

The excess distribution taxes (the creditable foreign taxes
attributable to an excess distribution) are allocated in the same
manner as the excess distribution is allocated. See the instructions
for Lines 9b and 10 and Line 14, earlier. Those taxes allocated to
pre-PFIC tax years and the election year are taken into account for
the election 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 16

This amount is the aggregate increases in taxes on the excess
distribution within the meaning of section 1291(c)(2).

Line 17

Compute the interest 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 election year.

Lines 18 and 19

The line 18 subtotal represents all amounts due as of the due date
(without regard to extensions) of the shareholder's income tax return
for the election year. The shareholder making the late deemed
dividend or late deemed sale election must pay additional interest on
the amount on line 18 from the due date (without regard to
extensions) of its income tax return for the election year up to and
including the date the Form 8621-A and payment are filed with the
IRS. Include this interest amount on line 19.

Closing Agreement

If the election year is a closed tax year, file the closing agreement on
page 3 of the form in duplicate. Both copies must contain original
signatures. Photocopies of signatures aren’t acceptable. The closing
agreement on page 3 of the actual form you file is the IRS copy. The
photocopy of the closing agreement that you attach to the 4-page
form is the taxpayer copy. Write “Taxpayer Copy” in the upper margin
of this copy. File the taxpayer copy as the first attachment after the
4-page form. The taxpayer copy will be returned to you after an
authorized IRS official has signed it.
Identifying number. Individuals should enter a social security
number or taxpayer identification number issued by the IRS. Entities
must enter an employer identification number.

Balance Sheet

If the shareholder is making a late deemed sale election with respect
to a former PFIC or a Section 1297(e) PFIC (Election B or D), the
shareholder is required to complete the balance sheet on page 4 of
Form 8621-A.

Note. If the PFIC uses the U.S. dollar approximate separate
transactions method of accounting (DASTM), the balance sheet
should be prepared and translated into U.S. dollars according to
Regulations section 1.985-3(d), rather than U.S. GAAP.

Instructions for Form 8621-A (Rev. 12-2024)

Line 11
You must attach to Form 8621-A a written narrative for each
intangible asset describing how the asset valuation was determined.
This narrative must include all pertinent valuation information
including whether the valuation was done by a third party. If the
valuation was done by a third party, include the name and business
address of that third party in the narrative.
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.
You must fill in all parts of the tax form that apply to you. If you
don’t file a return under circumstances requiring its filing, don’t
provide the information we ask for, or provide fraudulent information,
you may be charged penalties and be subject to criminal
prosecution. Section 6109 requires return preparers to provide their
identifying numbers on the return.
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, the District of Columbia, and U.S.
commonwealths and possessions 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 aren’t 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 of any Internal Revenue
law.
The time needed to complete and file this form will vary
depending on individual circumstances. The estimated burden for
individual and business taxpayers filing this form is approved under
OMB control numbers 1545-0074 and 1545-0123. The estimated
burden for all other taxpayers who file this form is shown below.
Recordkeeping . . . . . . . . . . . . . . . . . . .

22 hr., 43 min.

Learning about the law or the form. . . . . .

10 hr., 43 min.

Preparing the form . . . . . . . . . . . . . . . .

27 hr., 24 min.

Sending the form to the IRS . . . . . . . . . .

4 hr., 33 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 send us comments from IRS.gov/
FormsComments. You can write to the Internal Revenue Service, Tax
Forms and Publications, 1111 Constitution Ave. NW, IR-6526,
Washington, DC 20224. Don’t send the tax form to this address.
Instead, see Where To File, earlier.

5


File Typeapplication/pdf
File TitleInstructions for Form 8621-A (Rev. December 2024)
SubjectInstructions for Form 8621-A, Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Invest
AuthorW:CAR:MP:FP
File Modified2025-01-29
File Created2025-01-27

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