Opting Out of PFIC Tax-and-Interest Treatment: Making QEF Elections on Form 8621 Part II
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with a guide to the complex Qualified Election Fund (QEF) election rules for foreign investments that qualify as a Passive Foreign Investment Company (PFIC). The panel will go beyond the mechanics of PFIC reporting to detail the advantages, disadvantages and calculations involved in making a QEF election. The webinar will discuss making a “deemed sale election” after the year of purchase, detail how to report the election on Form 8621, and define the planning opportunities in electing out of PFIC treatment.
Outline
- Possible advantages of QEF election
- Making election in year of purchase
- Making election in a subsequent year after initial purchase
- Mark-to-market elections
- Reporting the election on Form 8621 Part II
Benefits
The panel will discuss these and other important issues:
- Identifying assets that qualify as PFIC holdings
- Differentiating tax results between PFIC, mark-to-market and QEF scenarios
- Calculating tax impact of QEF election in a year subsequent to acquisition of the PFIC asset
- Where to report QEF and purging elections on Form 8621
Faculty

Steven D. Bortnick
Partner
Troutman Pepper Hamilton Sanders
Mr. Bortnick is a partner in the firm's tax practice group and focuses his practice on domestic and... | Read More
Mr. Bortnick is a partner in the firm's tax practice group and focuses his practice on domestic and international tax and private equity matters. He handles a broad range of cross-disciplinary transactions, including asset, stock, cross-border and domestic acquisitions, tax-free spinoffs, recapitalizations and reorganizations.
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William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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Thomas D. Phelan
Attorney
Pepper Hamilton
Mr. Phelan focuses his practice on tax law. He has written on tax law issues and co-authored an article with Steven... | Read More
Mr. Phelan focuses his practice on tax law. He has written on tax law issues and co-authored an article with Steven Bortnick,Planning For Qualified Dividend Income When Taking Foreign Companies Public.
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