Form 8621 PFIC Reporting: Navigating the Highly Complex IRS Passive Foreign Investment Company Rules
Determining Which Assets Require PFIC Reporting, Calculating Tax and Interest, Leveraging QEF Elections
Recording of a 110-minute CPE webinar with Q&A
This webinar will furnish tax advisers with a thorough and practical guide to the reporting of investments in a passive foreign investment company (PFIC) on IRS Form 8621. The panel will identify those investments that require PFIC reporting, outline the various elections available to taxpayers holding interests in PFICs and discuss the tax implications of those elections, and will provide an example of a completed Form 8621 to illustrate reporting requirements.
Outline
- Identifying PFIC investments subject to filing requirements
- Filing thresholds and key exclusions
- Elections available to taxpayers
- Mark-to-market
- QEF election
- Completing Form 8621
Benefits
The panel will discuss these and other important issues:
- Types of foreign investments that must be reported as PFIC holdings
- Calculating the “tax and interest” on PFICs under IRC 1291
- Available elections to opt out of PFIC treatment
- Tax effects of these elections, from a tax due and a reporting standpoint
- Completing a Form 8621 to report PFIC holdings, including reporting elections
Faculty
Steven Flynn
Partner
W.L. Dueck & Co.
Mr. Flynn concentrates in the area of Canadian and US cross-border tax. His practice includes US and Canadian... | Read More
Mr. Flynn concentrates in the area of Canadian and US cross-border tax. His practice includes US and Canadian income tax planning and compliance for both individuals and businesses. He provides income tax advice on US investment and operations in Canada, Canadian investment and operations in the US, investment in US and Canadian real property, employee or individual emigration and/or temporary relocation and the Canada-US Income Tax Treaty.
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Mehrdad Ghassemieh
Partner
Harlowe & Falk
Mr. Ghassemieh's practice focuses on assisting companies of all sizes, in all business and tax matters,... | Read More
Mr. Ghassemieh's practice focuses on assisting companies of all sizes, in all business and tax matters, including advising closely held businesses to establish new business entities, advising on regulatory and tax matters, succession planning, and tax efficient planning for purchases or sales of existing businesses. He also provides tax consulting services to clients with international operations. His clients include both U.S.–based companies that have expanded abroad and foreign companies with U.S. ties. He also consults with U.S.–based exporting companies to determine whether they qualify for IC–DISC tax incentive benefits, and assists in both implementation and maintenance of IC–DISC structures.
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