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Department of the Treasury
Internal Revenue Service
Instructions for Form 8621-A

(Rev. November 2017)

(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 election is filed with the IRS. See the Complete Part IV of the form along with
unless otherwise noted. instructions for Part I, later, for details. any required attachments requested on any
of the lines in Part IV.
Future Developments How To Complete Form Sign and date the form in the spaces
provided at the bottom of page 2 of the form.
For the latest information about 8621-A If the election year is a closed taxable
developments related to Form 8621-A and The shareholder makes the applicable year, file the closing agreement on page 3 of
its instructions, such as legislation enacted election in Part I of the form. The shareholder the form in duplicate. Both copies must
after they were published, go to IRS.gov/ then provides basic information about the contain original signatures. See Closing
Form8621A. election in Part II or Part III of the form and Agreement, later, for details.
computes the tax and interest due in Part IV Complete the balance sheet on page 4 of
General Instructions of the form. the form, if applicable (that is, if required by
line 4 or line 8 of the form).
If the election year (defined below) is a Keep a copy of the form for your records.
Purpose of Form closed taxable year, the taxpayer must enter Make your check or money order payable
A U.S. person that is a direct or indirect into a closing agreement (page 3 of the form) to “United States Treasury.” Include your
shareholder of a former Passive Foreign to agree to eliminate any prejudice to the identifying number and “Form 8621-A” on
Investment Company (PFIC) or a Section interests of the U.S. government as a your payment.
1297(e) PFIC is treated for tax purposes as consequence of the taxpayer's inability to file
holding stock in a PFIC and therefore 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 The closing agreement must be filed CAUTION! line 21 of the form, the form won’t be
section 1291 unless the shareholder makes ! in duplicate and both copies must processed.
a purging election under section 1298(b)(1). CAUTION contain original signatures. See
A purging election under section 1298(b) Closing Agreement, later, for additional
(1) is: information. Definitions
A deemed dividend election or a deemed
sale election made with respect to a former A separate Form 8621-A must be filed Controlled Foreign Corporation
PFIC under the rules of Regulations sections for each PFIC for which a late purging (CFC)
1.1298-3(b) or 1.1298-3(c), or election is being made. See Chain of
A deemed dividend election or a deemed ownership below for specific filing See section 957(a) for definition.
sale election made with respect to a Section requirements.
1297(e) PFIC under the rules of Regulations Chain of ownership. If the shareholder CFC Overlap Rules
sections 1.1297-3(b) or 1.1297-3(c). owns one PFIC and through that PFIC owns A 10% U.S. shareholder (defined in section
A timely filed purging election is made on one or more other PFICs, the shareholder 951(b)) of a CFC that is also a PFIC that
Form 8621. must file a separate Form 8621-A for each includes in income its pro rata share of
Section 1297(e) PFIC or former PFIC in the subpart F income of the CFC generally won’t
Form 8621-A is used only to make a late chain for which a late purging election is be subject to the PFIC provisions for the
purging election under section 1298(b)(1). A made. The shareholder files these Forms same stock during the qualified portion of the
late purging election is a purging election 8621-A together. shareholder's holding period of the stock in
under section 1298(b)(1) that is made: the PFIC. This exception doesn’t apply to
In the case of a shareholder of a former Where To File option holders. For more information, see
PFIC, after 3 years from the due date, as section 1297(d).
extended, of the tax return for the taxable File Form 8621-A with:
Qualified portion of holding period. For
year that includes the termination date, or Internal Revenue Service purposes of section 1297(d), the qualified
In the case of a shareholder of a section Deposit Team, M/S 6059 portion of the shareholder's holding period in
1297(e) PFIC, after 3 years from the due Attn: Specials Desk a corporation is the portion of the
date, as extended, of the tax return for the Ogden, UT 84201 shareholder's holding period:
taxable year that includes the CFC That is after December 31, 1997, and
qualification date. During which the shareholder is a U.S.
See Regulations sections 1.1298-3(e) or Filing Checksheet shareholder under section 951(b) and the
1.1297-3(e) for more details. Be sure to: corporation is a CFC.
Check the applicable box in Part I of the
Generally, the amount due with respect to form that corresponds to the election you are CFC qualification date. The CFC
a late purging election is computed in the making. qualification date is the first day on which the
same manner as if the purging election had Complete the applicable lines in Part II or qualified portion of the shareholder's holding
been timely filed. However, the taxpayer III of the form (along with any required period in the Section 1297(e) PFIC begins,
must also pay interest on the amount due attachments requested on any of those lines) as determined under section 1297(d).
determined for the period beginning on the as requested at the end of the election Section 1297(e) PFIC. A foreign
due date (without extensions) for the description in Part I of the form. corporation is a Section 1297(e) PFIC with
taxpayer's income tax return for the election respect to a shareholder if:
year and ending on the date the late purging

Oct 31, 2017 Cat. No. 39731G

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1. The foreign corporation qualifies as a under section 1297(e)) held by the foreign
PFIC under section 1297(a) on the first day corporation during the taxable year are Part I. Elections
on which the qualified portion of the assets that produce passive income or that
shareholder's holding period in the foreign are held for the production of passive Election A. Late Deemed
corporation begins, as determined under income. Dividend Election With Respect
section 1297(d) (CFC overlap rule), and
2. The stock of the foreign corporation Basis for measuring assets. When to a Former PFIC
held by the shareholder is treated as stock of determining PFIC status using the asset test, This is a deemed dividend election under
a PFIC, under section 1298(b)(1), because, a foreign corporation can use adjusted basis section 1298(b)(1) that is made with respect
at any time during the shareholder's holding if: to a former PFIC after the time prescribed in
period of the stock, other than the qualified 1. The corporation isn’t publicly traded Regulations section 1.1298-3(c)(4) has
portion, the corporation was a PFIC that for the taxable year and elapsed.
wasn’t a QEF. 2. The corporation (a) is a CFC or (b)
makes an election to use adjusted basis. Who Can Make the Election
Election Year This election can be made by a U.S. person
Publicly traded corporations must use fair
In the case of a former PFIC, the election market value when determining PFIC status that is a shareholder of a foreign corporation
year is the taxable year of the electing using the asset test. that is a former PFIC with respect to such
shareholder that includes the termination shareholder provided the foreign corporation
date. Look-thru rule. When determining if a was a CFC during the last taxable year as a
In the case of a Section 1297(e) PFIC, the foreign corporation that owns at least 25% PFIC.
election year is the taxable year of the (by value) of another corporation is a PFIC,
electing shareholder that includes the CFC the foreign corporation is treated as if it held Effect of Election
qualification date. a proportionate share of the assets and
Former PFIC received directly its proportionate share of A shareholder making this election is treated
the income of the 25%-or-more owned as receiving a dividend of its pro rata share
A foreign corporation is a former PFIC with corporation. of the post-1986 earnings and profits of the
respect to the shareholder if the corporation former PFIC on the termination date. The
satisfies neither the income test nor the asset Qualified Electing Fund (QEF) deemed dividend is taxed under section
test (described under the definition of PFIC A PFIC is a QEF if the U.S. person who is a 1291 as an excess distribution, allocated
below), but whose stock, held by that direct or indirect shareholder of the PFIC only to the days in the shareholder's holding
shareholder, is treated as stock of a PFIC, elects (under section 1295) to treat the PFIC period during which the foreign corporation
under section 1297(b)(1), because at any as a QEF. See the instructions for Form 8621 qualified as a PFIC. For this purpose, the
time during the shareholder's holding period for more information. shareholder's holding period ends on the
of the stock the corporation was a PFIC termination date. After the deemed dividend
(under the income or asset test of section Shareholder election, the shareholder's stock isn’t treated
1297(a) described below) that wasn’t a QEF, A shareholder is a U.S. person that is a as stock in a PFIC unless the foreign
and the shareholder hasn’t made a direct or indirect shareholder of the foreign corporation thereafter qualifies as a PFIC.
mark-to-market election with respect to the corporation. See Indirect shareholder,
PFIC. earlier, for definition. Special Rules
Indirect Shareholder Termination Date For purposes of this election, the following
Generally, a U.S. person is an indirect The termination date is the last day of the apply.
shareholder of a Section 1297(e) PFIC or a last taxable year of the foreign corporation The basis of the shareholder's stock is
former PFIC if it is: during which it qualified as a PFIC under increased by the amount of the deemed
1. A direct or indirect owner of a section 1297(a). dividend. The manner in which the basis
pass-through entity that is a direct or indirect adjustment is made depends on whether the
shareholder of a Section 1297(e) PFIC or a shareholder is a direct or indirect
former PFIC, Specific Instructions shareholder. See Regulations section
1.1298-3(c)(6).
2. A shareholder of a PFIC that is a For purposes of the PFIC rules only, the
shareholder of a Section 1297(e) PFIC, or a Address and Identifying shareholder's new holding period begins on
former PFIC, Number the day following the termination date.
3. A 50%-or-more shareholder of a The term “post-1986 earnings and profits”
foreign corporation that isn’t a PFIC and that Address. Include the suite, room, or other
directly or indirectly owns stock of a Section unit number after the street address. If the means the undistributed earnings and profits
1297(e) PFIC or a former PFIC, or Post Office doesn’t deliver mail to the street of the PFIC (as of the close of the taxable
address and the shareholder has a P.O. box, year that includes the termination date
4. A 50%-or-more shareholder of a enter the box number instead. without reduction for dividends distributed
domestic corporation that owns a section during the taxable year) accumulated in tax
1291 fund. Identifying number. Individuals should years beginning after 1986 during which the
enter a social security number or taxpayer CFC was a PFIC and while the shareholder
Passive Foreign Investment identification number issued by the IRS. held the stock.
Company (PFIC) Entities must enter an employer identification
number.
A foreign corporation is a PFIC if it meets Line 3 Attachment
either the income or asset test described Shareholder Contact Information. If the The shareholder must attach a statement to
below. person to contact with respect to Form Form 8621-A that shows the calculation of its
1. Income test. 75% or more of the 8621-A is the taxpayer, enter “Same” in the pro rata share of the post-1986 earnings and
corporation's gross income for its taxable entry space for the name. If the person to profits of the former PFIC that is treated as
year is passive income (as defined in section contact with respect to Form 8621-A is a distributed to the shareholder on the
1297(b)). person other than the taxpayer, enter the termination date. The post-1986 earnings
information requested and attach Form and profits can be reduced (but not below
2. Asset test. At least 50% of the 2848. zero) by the amount that the shareholder
average percentage of assets (determined
satisfactorily shows was previously included

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in its income or in the income of another U.S. that loss cannot be recognized. In addition, Line 7 Attachment
person. The shareholder shows this by there is no basis adjustment for a loss.
including in the statement mentioned above The shareholder must attach a statement to
Form 8621-A that shows the calculation of its
the following information: How To Make the Election pro rata share of the post-1986 earnings and
The name, address, and identifying
number of the U.S. person and the amount To make this election, check box B in Part I profits of the Section 1297(e) PFIC that is
that was previously included in income; and complete Part II, lines 1, 2, and 4, and treated as distributed to the shareholder on
The tax year in which the amount was Part IV. the CFC qualification date. The post-1986
previously included in income; earnings and profits can be reduced (but not
The provision of law under which the For more information regarding making below zero) by the amount that the
amount was previously included in income; Election B, see Regulations section shareholder satisfactorily shows was
A description of the transaction in which 1.1298-3(b) and Regulations section previously included in its income or in the
the shareholder acquired the stock of the 1.1298-3(e). income of another U.S. person. The
former PFIC from the other U.S. person; and shareholder shows this by including in the
The provision of law under which the Election C. Late Deemed statement mentioned above the following
shareholder's holding period includes the Dividend Election With Respect information:
The name, address, and identifying
holding period of the other U.S. person. to a Section 1297(e) PFIC number of the U.S. person and the amount
This is a deemed dividend election under that was previously included in income;
How To Make the Election section 1298(b)(1) that is made by a The tax year in which the amount was
To make this election, check box A in Part I shareholder (defined earlier) with respect to previously included in income;
and complete Part II, lines 1, 2, and 3, and a Section 1297(e) PFIC that is also a CFC A description of the transaction in which
Part IV. after the time prescribed in Regulations the shareholder acquired the stock of the
section 1.1297-3(c)(4) has elapsed. Section 1297(e) PFIC from the other U.S.
For more information on making Election person; and
A, see Regulations section 1.1298-3(c) and Who Can Make the Election The provision of law under which the
Regulations section 1.1298-3(e). shareholder's holding period includes the
The election can be made by a shareholder holding period of the other U.S. person.
Election B. Late Deemed Sale of a foreign corporation that is a Section
1297(e) PFIC with respect to that
Election With Respect to a shareholder. How To Make the Election
Former PFIC To make this election, check box C in Part I
This is a deemed sale election under section Effect of Election and complete Part III, lines 5, 6, and 7, and
1298(b)(1) that is made with respect to a Part IV.
former PFIC after the time prescribed in A shareholder making this election is treated
Regulations section 1.1298-3(b)(3) has as receiving a dividend of its pro rata share For more information on making Election
elapsed. of the post-1986 earnings and profits of the C, see Regulations sections 1.1297-3(c) and
Section 1297(e) PFIC on the CFC (e).
qualification date. The deemed dividend is
Who Can Make the Election taxed under section 1291 as an excess Election D. Late Deemed Sale
This election can be made by a U.S. person distribution, allocated only to the days in the Election With Respect to a
that is a shareholder of a former PFIC. shareholder's holding period during which
the foreign corporation qualified as a PFIC. Section 1297(e) PFIC
For this purpose, the shareholder's holding This is a deemed sale election under section
Effect of Election period ends on the day before the CFC 1298(b)(1) that is made with respect to a
A shareholder making this election is qualification date. After the deemed dividend Section 1297(e) PFIC after the time
deemed to have sold the former PFIC stock election, the shareholder's stock isn’t treated prescribed in Regulations section
on the termination date for its fair market as stock in a PFIC unless the qualified 1.1297-3(b)(3) has elapsed.
value. The gain from the deemed sale is portion of the shareholder's holding period
taxed under section 1291 as an excess ends, and the foreign corporation thereafter Who Can Make the Election
distribution received on the termination date. qualifies as a PFIC.
After the deemed sale election, the This election can be made by a U.S. person
that is a shareholder of a foreign corporation
shareholder's stock isn’t treated as stock in a Special Rules that is a section 1297(e) PFIC with respect to
PFIC unless the foreign corporation
thereafter qualifies as a PFIC. For the purpose of this election, the following such shareholder.
apply:
The basis of the shareholder's stock is Effect of Election
Special Rules increased by the amount of the deemed
For purposes of this election, the following dividend. The manner in which the basis A shareholder making this election is
apply. adjustment is made depends on whether the deemed to have sold the Section 1297(e)
The basis of the shareholder's stock is shareholder is a direct or indirect PFIC stock on the CFC qualification date for
increased by the gain recognized on the shareholder. See Regulations section its fair market value. The gain from the
deemed sale. The manner in which the basis 1.1297-3(c)(6). deemed sale is taxed under section 1291 as
adjustment is made depends on whether the For purposes of the PFIC rules only, the an excess distribution received on the CFC
shareholder is a direct or indirect shareholder's new holding period begins on qualification date. After the deemed sale
shareholder. See Regulations section the CFC qualification date. election, the shareholder's stock isn’t treated
1.1298-3(b)(5). The term “post-1986 earnings and profits” as stock in a PFIC unless the qualified
For purposes of the PFIC rules only, the means the undistributed earnings and profits portion of the shareholder's holding period
shareholder's new holding period of the of the PFIC (as of the day before the CFC ends, and the foreign corporation thereafter
stock begins on the day following the qualification date) accumulated in taxable qualifies as a PFIC.
termination date. years beginning after 1986 during which the
The election can be made for stock on CFC was a PFIC and while the shareholder
which the shareholder will realize a loss, but held the stock.

Instructions for Form 8621-A (Rev. 11-2017) -3-

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Special Rules a PFIC (pre-PFIC years) and amounts the due date (without regard to extensions)
allocated to the election year. Enter the sum of your income tax return for the election
For purposes of this election, the following on line 10. year.
apply. With respect to the amounts allocated to
The basis of the shareholder's stock is each tax year in your holding period other Lines 18 and 19
increased by the gain recognized on the than the election year and the pre-PFIC The line 18 subtotal represents all amounts
deemed sale. The manner in which the basis years, see the instructions for line 14. due as of the due date (without regard to
adjustment is made depends on whether the extensions) of the shareholder's income tax
shareholder is a direct or indirect return for the election year. The shareholder
shareholder. See Regulations section Lines 11 and 12
making the late deemed dividend or late
1.1297-3(b)(5). The shareholder's income tax liability is deemed sale election must pay additional
For purposes of the PFIC rules only, the generally the amount shown on the “total tax” interest on the amount on line 18 from the
shareholder's new holding period begins on line of the return. due date (without regard to extensions) of its
the CFC qualification date. income tax return for the election year up to
The election can be made for stock on Line 14
and including the date the Form 8621-A and
which the shareholder will realize a loss, but Determine the increase in tax for each tax payment are filed with the IRS. Include this
that loss cannot be recognized. In addition, year in your holding period other than the interest amount on line 19.
there is no basis adjustment for a loss. election year and pre-PFIC years (that is, for
each PFIC year). An increase in tax is
How To Make the Election determined for each PFIC year by multiplying Closing Agreement
the part of the distribution or disposition If the election year is a closed taxable year,
To make this election, check box D in Part I allocated to each year (see Lines 9b and 10, file the closing agreement on page 3 of the
and complete Part III, lines 5, 6, and 8, and earlier) by the highest rate of tax under form in duplicate. Both copies must contain
Part IV. section 1 or section 11, whichever applies, in original signatures. Photocopies of
effect for that tax year. Add the increases in signatures aren’t acceptable. The closing
For more information on making Election tax computed for all PFIC years. Enter the agreement on page 3 of the actual form you
D, see Regulations sections 1.1297-3(b) and aggregate increases in tax (before credits) file is the IRS copy. The photocopy of the
(e). on line 14. closing agreement that you attach to the
4-page form is the taxpayer copy. Write
Line 15 “Taxpayer Copy” in the upper margin of this
Part IV. Computation of To figure the foreign tax credit, figure the copy. File the taxpayer copy as the first
Tax and Interest Due total creditable foreign taxes attributable to attachment after the 4-page form. The
the excess distribution (line 9a) amount. This taxpayer copy will be returned to you after an
Line 9a amount includes, for 10% or greater authorized IRS official has signed it.
Enter the amount treated as an excess corporate shareholders, any taxes deemed Identifying number. Individuals should
distribution under the deemed dividend or paid under section 902. Both the direct and enter a social security number or taxpayer
deemed sale election. This amount is: indirect foreign taxes must be creditable identification number issued by the IRS.
In the case of a former PFIC making a under general foreign tax credit principles, Entities must enter an employer identification
deemed dividend election, the amount on and the shareholder must choose to claim number.
line 3 of Part II. the foreign tax credit.
In the case of a former PFIC making a The excess distribution taxes (the Balance Sheet
deemed sale election, the amount on line 4 creditable foreign taxes attributable to an If the shareholder is making a late deemed
of Part II. excess distribution) are allocated in the sale election with respect to a former PFIC or
In the case of a Section 1297(e) PFIC same manner as the excess distribution is a Section 1297(e) PFIC (Election B or D), the
making a deemed dividend, the amount on allocated. See the instructions for Lines 9b shareholder is required to complete the
line 7 of Part III. and 10 and Line 14, earlier. Those taxes balance sheet on page 4 of Form 8621-A.
In the case of a Section 1297(e) PFIC allocated to pre-PFIC tax years and the
making a deemed sale election, the amount election year are taken into account for the Note. If the PFIC uses the U.S. dollar
on line 8 of Part III. election year under the general rules of the approximate separate transactions method
Lines 9b and 10 foreign tax credit. of accounting (DASTM), the balance sheet
Determine the allocation of the excess The excess distribution taxes allocated to should be prepared and translated into U.S.
distribution to all applicable taxable years on a PFIC year only reduce the increase in tax dollars according to Regulations section
a separate sheet and attach it to Form figured for that tax year (but not below zero). 1.985-3(d), rather than U.S. GAAP.
8621-A. Divide the amount on line 9a by the No carryover of any unused excess
number of days in your holding period. The distribution taxes is allowed. Line 11
holding period of the stock is treated as You must attach to Form 8621-A a written
ending on: When you dispose of PFIC stock, the
The termination date, in the case of a above foreign tax credit rules apply only to narrative for each intangible asset describing
former PFIC making a deemed sale or the part of the gain that, without regard to how the asset valuation was determined.
deemed dividend election; section 1291, would be treated under section This narrative must include all pertinent
The CFC qualification date, in the case of 1248 as a dividend. valuation information including whether the
valuation was done by a third party. If the
a Section 1297(e) PFIC making a deemed Line 16 valuation was done by a third party, include
sale election; and the name and business address of that third
The day before the CFC qualification This amount is the aggregate increases in
date, in the case of a Section 1297(e) PFIC taxes on the excess distribution within the party in the narrative.
making a deemed dividend election. meaning of section 1291(c)(2).
Disclosure, Privacy Act, and Paperwork
Determine the amount allocable to each Line 17 Reduction Act Notice. We ask for the
tax year in your holding period by adding the Compute the interest on each net increase in information on this form to carry out the
amounts allocated to the days in each such tax for the period beginning on the due date Internal Revenue laws of the United States.
tax year. Then: (without regard to extensions) of your Sections 6001, 6011, 6012(a), 6103, and
Add the amounts allocated to the tax income tax return for the tax year to which an 6109, and their regulations, require you to
years before the foreign corporation became increase in tax is attributable and ending with provide this information. We need this

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information to ensure that you are complying     District of Columbia, and U.S.                  Recordkeeping. . . . . . . . .       22 hr., 43 min.
with the Internal Revenue laws and to allow      commonwealths and possessions for use in 
us to figure and determine the right amount      administering their tax laws, to federal and    Learning about the law or 
of tax.                                          state agencies to enforce federal nontax        the form. . . . . . . . . . . . . .  10 hr., 43 min.
                                                 criminal laws, or to federal law enforcement    Preparing the form . . . . . .       27 hr., 24 min.
You must fill in all parts of the tax form       and intelligence agencies to combat 
that apply to you. If you don’t file a return    terrorism.                                      Sending the form to the 
under circumstances requiring its filing, don’t                                                  IRS. . . . . . . . . . . . . . . . .  4 hr., 33 min.
provide the information we ask for, or provide   You aren’t required to provide the 
fraudulent information, you may be charged       information requested on a form that is 
penalties and be subject to criminal             subject to the Paperwork Reduction Act 
prosecution. Section 6109 requires return        unless the form displays a valid OMB control    If you have comments concerning the 
preparers to provide their identifying           number. Books or records relating to a form     accuracy of these time estimates or 
numbers on the return.                           or its instructions must be retained as long as suggestions for making this form simpler, we 
Generally, tax returns and return                their contents may become material in the       would be happy to hear from you. You can 
information are confidential, as required by     administration of any Internal Revenue law.     send us comments from IRS.gov/
                                                                                                 FormsComments. You can write to the 
section 6103. However, section 6103 allows                                                       Internal Revenue Service, Tax Forms and 
or requires the Internal Revenue Service to      The time needed to complete and file this 
disclose or give the information shown on        form will vary depending on individual          Publications, 1111 Constitution Ave. NW, 
your tax return to others as described in the    circumstances. The estimated burden for         IR-6526, Washington, DC 20224. Don’t send 
Code. For example, we may disclose your          individual and business taxpayers filing this   the tax form to this address. Instead, see 
tax information to the Department of Justice     form is approved under OMB control              Where To File, earlier.
for civil and criminal litigation. We may also   numbers 1545-0074 and 1545-0123. The 
disclose this information to cities, states, the estimated burden for all other taxpayers who 
                                                 file this form is shown below.

Instructions for Form 8621-A (Rev. 11-2017)                 -5-

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