Generally, a U.S. person that is a direct or indirect shareholder of a PFIC must file Form 8621 for each tax year under the following five circumstances if the U.S. person: Is required to file an annual report pursuant to section 1298 (f).

All PFICs that do not currently have Mark to Market or Qualifying Electing Fund elections are taxed under § 1291 of the Internal Revenue Code. § 1291 taxation is very complex and convoluted but the basic premise is that the taxpayer will be treated as if any gain in the investment were received evenly over the period of ownership and that the ...

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

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2021年5月6日 · Title: Recommendation for Performance Recognition Form #: GSA1291 Current Revision Date: 03/2021 Authority or Regulation: HRM 9451.2 Special Instructions: Please ensure to download and save the form to your computer/device before using as the form is only compatible when opened directly in Adobe Acrobat or Adobe Reader software.

2023年7月14日 · Every time you receive an excess distribution, the holding period starts with the date of acquisition of the PFIC shares and ends with the date you received the distribution. IRC § 1291 (a) (3) (A) (i) says to treat the date of the distribution as the end of the holding period for purposes of allocating the excess distribution and calculating tax.

(1) Distributions.—If a United States person receives an excess distribution in respect of stock in a passive foreign investment company, then— (A) the amount of the excess distribution shall be allocated ratably to each day in the taxpayer’s holding period for the stock,

2018年1月7日 · Preview the Form 8621 calculation worksheets, TPS entry options (for ProSystem fx, Global fx, and Axcess Tax users) and the tax return forms that are being used by the fund.