Form 8621 PFIC Reporting: Passive Foreign Investment Company Rules After Tax Reform
Subpart F Expansion, New U.S. Shareholder Rules, Dealing With Dual CFC/PFIC Status, QEF Elections, Calculating Tax and Interest
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive 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.
- Code provisions governing PFIC treatment, purging, and deemed distribution rules
- Section 1291 default treatment
- Section 1295 QEF provisions
- Section 1296 mark-to-market option
- Section 1298 special rules
- Ownership rules
- When a pass-through entity owns PFIC shares
- When a trust or estate owns PFIC shares
- Rules when a foreign corporation or entity is classified as both a PFIC and a controlled foreign corporation
- Purging elections to remove PFIC "taint"
- Making election in the year of purchase
- Making election in a subsequent year after initial purchase
- Mark-to-market elections
- Entity classification elections
- Completing Form 8621
The panel will discuss these and other relevant topics:
- The legal background of PFICs and general rules
- Locating and interpreting PFIC information on foreign fund statements
- Identifying and calculating "excess distributions" under the PFIC rules
- Calculating tax and interest on eligible distributions
- Tax treatment of distributions not considered "excess"
- Alternate options and elections for PFICs
John Bowlby, J.D.
Mr. Bowlby has experience advising foreign and domestic businesses, trusts and estates, flow-throughs, and individuals... | Read More
Mr. Bowlby has experience advising foreign and domestic businesses, trusts and estates, flow-throughs, and individuals on cross-border activities, compliance, and most recently, the TCJA. Mr. Bowlby has worked on both the fund and investor sides of PFICs and has been a trusted resource and advisor to large foreign fund managers and institutional and private equity investors.Close
International Tax Manager
Ms. Kozar provides strategic advice to national clients from a wide variety of industries, including technology and... | Read More
Ms. Kozar provides strategic advice to national clients from a wide variety of industries, including technology and life sciences, on inbound and outbound U.S. international tax issues. She has helped clients work through the treatment and classification of controlled foreign corporations and passive foreign investment companies, as well as transfer pricing issues and the consequences of cross-border transfers of intellectual property, among other matters. Following the 2017 U.S. tax reform, Mr. Kozar has also helped clients implement and understand the new tax law, including the Base Erosion AntiAbuse Tax, and the Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income regimes.Close
Barbara E. Rasch
Ms. Rasch’s practice focuses on complex international transactional matters. She advises clients on U.S.... | Read More
Ms. Rasch’s practice focuses on complex international transactional matters. She advises clients on U.S. international tax matters, with an emphasis on outbound tax issues. In particular, she has experience advising on issues relating to the subpart F and passive foreign investment company rules. More recently, she has focused on helping clients navigate U.S. tax reform, including the new regimes for global intangible low-taxed income and foreign-derived intangible income. Prior to joining KPMG in October 2016, Ms. Rasch was with the Internal Revenue Service’s Office of Associate Chief Counsel (International) for seven years.Close
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