Selecteer taal

Formulier 8621-A Instructies

Instructies voor formulier 8621-A, Return by a Shareholder Making certain Late Elections To End Treatment as a Passive Foreign Investment Company

December 2018

Gerelateerde formulieren

  • Formulier 8621-A - Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company
Details
Bestandsformaat PDF
Maat 135.3 KB
Downloaden
Department of the Treasury  
Internal Revenue Service  
Instructions for Form 8621-A  
(Rev. December 2018)  
(Use with the December 2013 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.  
election is filed with the IRS. See the  
Complete Part IV of the form along with  
instructions for Part I, later, for details.  
any required attachments requested on any  
of the lines in Part IV.  
Sign and date the form in the spaces  
Future Developments  
How To Complete Form  
8621-A  
provided at the bottom of page 2 of the form.  
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/  
If the election year is a closed tax year, file  
The shareholder makes the applicable  
election in Part I of the form. The shareholder  
then provides basic information about the  
election in Part II or Part III of the form and  
computes the tax and interest due in Part IV  
of the form.  
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).  
General Instructions  
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  
Keep a copy of the form for your records.  
Make your check or money order payable  
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  
to “United States Treasury.” Include your  
identifying number and “Form 8621-A” on  
your payment.  
consequence of the taxpayer's inability to file  
an amended return for the election year.  
If Form 8621-A doesn't include full  
payment of the amount shown on  
continues to be subject to taxation under  
section 1291 unless the shareholder makes  
a purging election under section 1298(b)(1).  
!
The closing agreement must be filed  
CAUTION  
line 21 of the form, the form won’t be  
in duplicate and both copies must  
!
processed.  
CAUTION  
contain original signatures. See  
Closing Agreement, later, for additional  
A purging election under section 1298(b)  
(1) is:  
information.  
Definitions  
A deemed dividend election or a deemed  
Controlled Foreign Corporation  
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.  
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  
(CFC)  
See section 957(a) for definition.  
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).  
CFC Overlap Rules  
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.  
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).  
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  
Where To File  
PFIC, after 3 years from the due date, as  
extended, of the tax return for the tax year  
that includes the termination date, or  
File Form 8621-A with:  
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  
Internal Revenue Service  
Deposit Team, M/S 6059  
Attn: Specials Desk  
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.  
Ogden, UT 84201  
shareholder's holding period:  
That is after December 31, 1997, and  
During which the shareholder is a U.S.  
Filing Checksheet  
shareholder under section 951(b) and the  
corporation is a CFC.  
See Regulations sections 1.1298-3(e) or  
1.1297-3(e) for more details.  
Be sure to:  
Check the applicable box in Part I of the  
CFC qualification date. The CFC  
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  
form that corresponds to the election you are  
making.  
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).  
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.  
Section 1297(e) PFIC. A foreign  
corporation is a Section 1297(e) PFIC with  
respect to a shareholder if:  
taxpayer's income tax return for the election  
year and ending on the date the late purging  
Nov 26, 2018  
Cat. No. 39731G  
   
1. The foreign corporation qualifies as a  
PFIC under section 1297(a) on the first day  
on which the qualified portion of the  
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.  
Part I. Elections  
Election A. Late Deemed  
Dividend Election With Respect  
to a Former PFIC  
shareholder's holding period in the foreign  
corporation begins, as determined under  
section 1297(d) (CFC overlap rule), and  
Basis for measuring assets. When  
determining PFIC status using the asset test,  
a foreign corporation can use adjusted basis  
if:  
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.  
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.  
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.  
Who Can Make the Election  
Election Year  
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.  
In the case of a former PFIC, the election  
year is the tax year of the electing  
shareholder that includes the termination  
date.  
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.  
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.  
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  
Former PFIC  
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  
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.  
corporation thereafter qualifies as a PFIC.  
mark-to-market election with respect to the  
PFIC.  
Special Rules  
Termination Date  
Indirect Shareholder  
For purposes of this election, the following  
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).  
Generally, a U.S. person is an indirect  
shareholder of a Section 1297(e) PFIC or a  
former PFIC if it is:  
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).  
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.  
Specific Instructions  
Address and Identifying  
For purposes of the PFIC rules only, the  
Number  
shareholder's new holding period begins on  
the day following the termination date.  
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.  
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.  
Identifying number. Individuals should  
enter a social security number or taxpayer  
identification number issued by the IRS.  
Entities must enter an employer identification  
number.  
Passive Foreign Investment  
Company (PFIC)  
Line 3 Attachment  
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.  
A foreign corporation is a PFIC if it meets  
either the income or asset test described  
below.  
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  
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)).  
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.  
2. Asset test. At least 50% of the  
average percentage of assets (determined  
-2-  
Instructions for Form 8621-A (Rev. 12-2018)  
         
person. The shareholder shows this by  
including in the statement mentioned above  
the following information:  
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.  
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  
The name, address, and identifying  
number of the U.S. person and the amount  
that was previously included in income;  
For more information regarding making  
Election B, see Regulations section  
1.1298-3(b) and Regulations section  
1.1298-3(e).  
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;  
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:  
A description of the transaction in which  
Election C. Late Deemed  
Dividend Election With Respect  
to a Section 1297(e) PFIC  
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.  
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.  
The name, address, and identifying  
number of the U.S. person and the amount  
that was previously included in income;  
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.  
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  
Who Can Make the Election  
For more information on making Election  
A, see Regulations section 1.1298-3(c) and  
Regulations section 1.1298-3(e).  
The election can be made by a shareholder  
of a foreign corporation that is a Section  
1297(e) PFIC with respect to that  
shareholder.  
The provision of law under which the  
shareholder's holding period includes the  
holding period of the other U.S. person.  
Election B. Late Deemed Sale  
Election With Respect to a  
Former PFIC  
Effect of Election  
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.  
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  
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.  
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.  
For more information on making Election  
C, see Regulations sections 1.1297-3(c) and  
(e).  
Who Can Make the Election  
Election D. Late Deemed Sale  
Election With Respect to a  
Section 1297(e) PFIC  
This election can be made by a U.S. person  
that is a shareholder of a former PFIC.  
Effect of Election  
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.  
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  
Special Rules  
Who Can Make the Election  
For the purpose of this election, the following  
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.  
shareholder's stock isn’t treated as stock in a  
PFIC unless the foreign corporation  
thereafter qualifies as a PFIC.  
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).  
Special Rules  
Effect of Election  
For purposes of this election, the following  
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.  
apply.  
The basis of the shareholder's stock is  
For purposes of the PFIC rules only, the  
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).  
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 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.  
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.  
Instructions for Form 8621-A (Rev. 12-2018)  
-3-  
allocated to the election year. Enter the sum  
on line 10.  
(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.  
Special Rules  
For purposes of this election, the following  
With respect to the amounts allocated to  
apply.  
each tax year in your holding period other  
than the election year and the pre-PFIC  
years, see the instructions for Line 14.  
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).  
Lines 18 and 19  
Lines 11 and 12  
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.  
The shareholder's income tax liability is  
generally the amount shown on the “total tax”  
line of the return.  
For purposes of the PFIC rules only, the  
shareholder's new holding period begins on  
the CFC qualification date.  
Line 14  
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.  
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.  
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.  
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  
For more information on making Election  
D, see Regulations sections 1.1297-3(b) and  
(e).  
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.  
Line 15  
To determine the foreign tax credit, the  
shareholder of a section 1291 fund  
Part IV. Computation of  
Tax and Interest Due  
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.  
Line 9a  
Enter the amount treated as an excess  
distribution under the deemed dividend or  
deemed sale election. This amount is:  
Identifying number. Individuals should  
enter a social security number or taxpayer  
identification number issued by the IRS.  
Entities must enter an employer identification  
number.  
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.  
Balance Sheet  
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.  
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.  
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  
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.  
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 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  
The termination date, in the case of a  
deemed sale or deemed dividend election  
for a former PFIC;  
Line 11  
distribution taxes is allowed.  
The CFC qualification date, in the case of  
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.  
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.  
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.  
Line 16  
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:  
This amount is the aggregate increases in  
taxes on the excess distribution within the  
meaning of section 1291(c)(2).  
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.  
Add the amounts allocated to the tax  
Line 17  
years before the foreign corporation became  
a PFIC (pre-PFIC years) and amounts  
Compute the interest on each net increase in  
tax for the period beginning on the due date  
-4-  
Instructions for Form 8621-A (Rev. 12-2018)  
     
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.  
for civil and criminal litigation. We may also  
disclose this information to cities, states, the  
District of Columbia, and U.S.  
estimated burden for all other taxpayers who  
file this form is shown below.  
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.  
Recordkeeping .  
.
.
.
.
.
.
.
. 22 hr., 43 min.  
Learning about the law or  
the form.  
.
.
.
.
.
.
.
.
.
.
.
.
.
. 10 hr., 43 min.  
. 27 hr., 24 min.  
Preparing the form  
.
.
.
.
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  
Sending the form to the  
IRS .  
You aren’t required to provide the  
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4 hr., 33 min.  
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.  
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/  
prosecution. Section 6109 requires return  
preparers to provide their identifying  
numbers on the return.  
Generally, tax returns and return  
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  
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.  
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  
numbers 1545-0074 and 1545-0123. The  
Instructions for Form 8621-A (Rev. 12-2018)  
-5-