This course is the first in the Passive Foreign Investment Companies series training, that gives a broad overview of the tax law related to passive foreign investment companies, or PFICs. Failing to properly file Form 8621 can expose your client to both onerous penalties and an unlimited statute of limitations for the assessment of tax. Even though the PFIC provisions are among the most complicated and punitive sections of the Internal Revenue Code, we will explain PFICs in plain English so you can explain them to your clients.
Learning Objectives:
Explain what qualifies as a PFIC and how to identify them.
Describe when a taxpayer must file Form 8621.
Compare and contrast the three different taxation regimes for PFICs.
Understand the potential penalties & statute of limitation issues with PFIC non-compliance.
This webinar will instruct in both the details and computations required to complete Form 8621 under the default §1291 regulations. This is a course aimed at practitioners that have an intermediate level of understanding of PFIC taxation. The materials will be computation-intensive and will cover both §1291 theory as well as application on Form 8621.
Learning Objectives:
Describe the overall §1291 mechanism and its purpose.
Compute both excess and non-excess distribution amounts under §1291.
Complete a basic Form 8621 using the §1291 regime.
Transfer the tax items from a completed Form 8621 using the §1291 regime to the tax return.
This webinar will instruct in both the details and computations required to complete Form 8621 under the qualified electing fund (QEF) and mark-to-market (MTM) regulations. This is a course aimed at practitioners that have an intermediate level of understanding of PFIC taxation. The materials will be computation-intensive and will cover both QEF and MTM theory as well as application on Form 8621.
Learning Objectives:
Describe the overall QEF and MTM mechanisms and their purposes.
Analyze the benefits and drawbacks of the QEF and MTM elections.
Complete a basic Form 8621 using the QEF and MTM regimes.
Transfer the tax items from a completed Form 8621 using the QEF and MTM regimes to the tax return.