New Code Section 1298(f) (recently enacted under the HIRE Act) requires shareholders of a passive foreign investment company (PFIC) to report such information as the IRS requires on an annual basis. Questions have been raised as to what and when taxpayers should now be reporting.
Even though this new provision is now in effect, the IRS is advising taxpayers that Form 8621, Return by a Shareholder of a Passive Foreign Investment Company or a Qualified Electing Fund, need only be filed under the old rules. New guidance will eventually be forthcoming that implements the new annual reporting requirements.
Notice 2010-34
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