This course will delve into the Form 8621 – Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund. In this course, we will:
- Review the statutory provisions requiring reporting
- Identify key concepts and investments that require PFIC reporting – will review both
direct and indirect investment
- Review various elections and tax implications of those elections available to those
Taxpayers holding PFICS and the “once a PFIC always a PFIC” rule
- Review the updates the IRS is seeking to make in this election space
- Discus the punitive interest charge when elections are not made
- Review filing requirements and how to avoid costly mistakes
- Review available options for remediation
Rita leads Wolf’s International Tax Practice, where she focuses on tax planning and compliance for international holdings. Rita has extensive experience advising clients on the tax aspects of cross-border business activities, structuring...
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