Instructions for Form 8621

Instructions for Form 8621

(Rev. December 2025)

Information Return by a Shareholder of a Passive Foreign Investment Company or

Qualified Electing Fund

Section references are to the Internal Revenue Code

unless otherwise noted.

Future Developments

For the latest information about developments relating to

Form 8621 and its instructions, such as legislation

enacted after they were published, go to IRS.gov/

Form8621.

What’s New

New Part V lines on page 3 of Form 8621. In the entry

space provided for the new line above line 15a, filers are

required to enter a three-letter currency code.

New line 15e(2) requests filers to report the line 15e(1)

amount in U.S. dollars. If the amount on line 15e(1) is in a

foreign currency, filers must convert the amount to U.S.

dollars.

See instructions for more information about both of

these new lines.

General Instructions

Who Must File

Qualifying Insurance Corporation

A U.S. person that owns stock (or holds an option to

purchase stock) of a foreign corporation and elects to treat

such stock as the stock of a qualifying insurance

corporation under the alternative facts and circumstances

test within the meaning of section 1297(f)(2) and

Regulations section 1.1297-4(d) must file a

limited-information Form 8621. For details, see Election To

Be Treated as a Qualifying Insurance Corporation, later.

Passive Foreign Investment Corporation (PFIC)

Generally, a U.S. person that is a direct or indirect

shareholder of a PFIC must file Form 8621 for each tax

year under the following five circumstances if the U.S.

person:

1. Receives certain direct or indirect distributions from

a PFIC,

2. Recognizes gain on a direct or indirect disposition

of PFIC stock,

3. Is reporting information with respect to a Qualified

Electing Fund (QEF) or section 1296 mark-to-market

election,

4. Is making an election reportable in Part II of the

form, or

5. Is required to file an annual report pursuant to

section 1298(f). See the Part I instructions, later, for more

information regarding the person that must file pursuant to

section 1298(f).

Dec 8, 2025

A separate Form 8621 must be filed for each PFIC in

which stock is held directly or indirectly. In the case of a

chain of ownership, under the five circumstances

described above, unless otherwise provided, if the

shareholder owns one PFIC and through that PFIC owns

one or more other PFICs, the shareholder must file a Form

8621 for each PFIC in the chain.

A single Form 8621 may be filed with respect to a PFIC

to report the information required by section 1298(f) (that

is, Part I), as well as to report information in Parts III

through VI of the form and to make elections in Part II of

the form. For example, a U.S. person that has made a

section 1296 mark-to-market election with respect to a

PFIC will file a single Form 8621 and complete Part I and

Part IV.

Indirect shareholder. Generally, a U.S. person is an

indirect shareholder of a PFIC if it is:

• A 50%-or-more shareholder of a foreign corporation

that is not a PFIC and that directly or indirectly owns stock

of a PFIC,

• A shareholder of a PFIC where the PFIC itself is a

shareholder of another PFIC, or

• A direct or indirect owner of a pass-through entity where

the pass-through entity itself is a direct or indirect

shareholder of a PFIC.

For more information on determining whether a U.S.

person is an indirect shareholder, see Regulations section

1.1291-1(b)(8).

For purposes of these rules, a pass-through entity is a

partnership, S corporation, trust, or estate.

However, a U.S. person that owns stock of a PFIC

through a tax-exempt organization or account described in

the list below is not treated as a shareholder of the PFIC.

• An organization or an account that is exempt from tax

under section 501(a) because it is described in section

501(c), 501(d), or 401(a).

• A state college or university described in section 511(a)

(2)(B).

• A plan described in section 403(b) or 457(b).

• An individual retirement plan or annuity as defined in

section 7701(a)(37).

• A qualified tuition program described in section 529 or

530.

• A qualified ABLE program described in section 529A.

Interest holder of pass-through entities. In general,

the following interest holders must file Form 8621, unless

an exception applies.

1. A U.S. person that is an interest holder of a foreign

pass-through entity that is a direct or indirect shareholder

of a PFIC.

Instructions for Form 8621 (Rev. 12-2025) Catalog Number 10784P

Department of the Treasury Internal Revenue Service www.irs.gov

2. A U.S. person that is considered (under sections

671 through 679) the shareholder of PFIC stock held in

trust.

3. A U.S. partnership, S corporation, U.S. trust (other

than a trust that is subject to sections 671 through 679 for

the PFIC stock), or U.S. estate that is a direct or indirect

shareholder of a PFIC.

Note: U.S. persons that are interest holders of

pass-through entities described in 3 above must file Form

8621 if the pass-through entity fails to file such form or the

U.S. person is required to recognize any income under

section 1291.

When and Where To File

Attach Form 8621 to the shareholder's tax return (or, if

applicable, partnership or exempt organization return) and

file both by the due date, including extensions, of the

return at the Internal Revenue Service Center where the

tax return is required to be filed.

If you are not required to file an income tax return or

other return for the tax year, file Form 8621 directly with

the Internal Revenue Service Center, Ogden, UT

84201-0201.

Definitions and Special Rules

Passive Foreign Investment Company (PFIC)

A foreign corporation is a PFIC if it meets either the

income or asset test described next.

1. Income test. 75% or more of the corporation's

gross income for its tax year is passive income (as defined

in section 1297(b)).

2. Asset test. At least 50% of the average percentage

of assets (determined under section 1297(e)) held by the

foreign corporation during the tax year are assets that

produce passive income or that are held for the production

of passive income.

Basis for measuring assets. When determining PFIC

status using the asset test, a foreign corporation must use

adjusted basis if:

1. The corporation is not publicly traded for the tax

year; and

2. The corporation is a controlled foreign corporation

(CFC) under Regulations section 1.1297-1(d)(1)(v)(B)(2).

In addition, a non-publicly traded foreign corporation

that is not a CFC may use adjusted basis if an election is

made to use adjusted basis. The election can be made

either by the corporation or by certain of its owners. If

made by an owner, the election must be made according

to the rules of Regulations section 1.1297-1(d)(1)(iv).

Publicly traded foreign corporations must use fair

market value when determining PFIC status using the

asset test. See Regulations section 1.1297-1(f)(7) for

guidance on when a foreign corporation is publicly traded

for this purpose.

Look-thru rule. When determining if a foreign

corporation is a PFIC, the foreign corporation is treated as

if it directly held its proportionate share of the assets and

directly received its proportionate share of the income of

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any corporation in which it owns at least 25% of the stock

(by value).

CFC overlap rule. A U.S. shareholder (defined in section

951(b)) that includes in income its pro rata share of

subpart F income for stock of a CFC that is also a PFIC

will not generally be subject to the PFIC provisions for the

same stock during the qualified portion of the

shareholder's holding period of the stock in the PFIC. This

exception does not apply to option holders. For more

information, see section 1297(d).

Note: The attribution rules of section 1298(a)(2)(B) will

continue to apply even if the foreign corporation is not

treated as a PFIC with respect to the shareholder under

section 1297(d).

Qualified Electing Fund (QEF) Election

A PFIC is a QEF if a U.S. person who is a direct or indirect

shareholder of the PFIC elects (under section 1295(b)) to

treat the PFIC as a QEF and complies with the

requirements described in section 1295(a)(2). See the

instructions for Election A, later, for information on making

this election.

Tax Consequences for Shareholders of a QEF

• A shareholder of a QEF must annually include in gross

income, as ordinary income, its pro rata share of the

ordinary earnings of the QEF and as long-term capital

gain its pro rata share of the net capital gain of the QEF.

• The shareholder may elect to extend the time for

payment of tax on its share of the undistributed earnings

of the QEF (Election B) until the QEF election is

terminated.

• If the QEF election is not made with respect to the first

year of the shareholder’s holding period in the PFIC, the

shareholder may be able to make a deemed sale election

(Election D) or deemed dividend election (Election E) (if

eligible). If the shareholder properly makes a deemed sale

election or deemed dividend election in connection with

its QEF election, then the PFIC will become a pedigreed

QEF (as defined in Regulations section 1.1291-9(j)(2)(ii))

with respect to the shareholder.

Note: A shareholder that receives a distribution from an

unpedigreed QEF (defined in Regulations section

1.1291-9(j)(2)(iii)) is also subject to the rules applicable to

a shareholder of a section 1291 fund, later.

Basis adjustments. A shareholder's basis in the stock of

a QEF, or in any property through which the shareholder is

treated as owning stock of a QEF, is increased by the

earnings included in gross income and decreased by a

distribution from the QEF to the extent of previously taxed

amounts.

Section 1291 Fund

A PFIC is a section 1291 fund if:

1. The shareholder did not elect to treat the PFIC as a

QEF or make a mark-to-market election with respect to

the PFIC, or

2. The PFIC is an unpedigreed QEF (as defined in

Regulations section 1.1291-9(j)(2)(iii)).

Instructions for Form 8621 (Rev. 12-2025)

Tax Consequences for Shareholders of a Section

1291 Fund

Shareholders of a section 1291 fund are subject to special

rules when they receive an excess distribution (defined

below) from, or recognize gain on the sale or disposition of

the stock of, a section 1291 fund. A distribution may be

partly or wholly an excess distribution. The entire amount

of gain from the disposition of a section 1291 fund is

treated as an excess distribution.

Excess distributions. An excess distribution is the part

of the distribution received from a section 1291 fund in the

current tax year that is greater than 125% of the average

distributions received in respect of such stock by the

shareholder during the 3 preceding tax years (or, if

shorter, the portion of the shareholder's holding period

before the current tax year). No part of a distribution

received or deemed received during the first tax year of

the shareholder's holding period of the stock will be

treated as an excess distribution.

The excess distribution is determined on a per share

basis and is allocated to each day in the shareholder's

holding period of the stock. See section 1291(b)(3) for

adjustments that are made when determining if a

distribution is an excess distribution.

Portions of an excess distribution are treated differently.

The portions allocated to the days in the current tax year

and the shareholder's tax years in its holding period

before the foreign corporation qualified as a PFIC

(pre-PFIC years) are taxed as ordinary income. The

portions allocated to the days in the shareholder's tax

years (other than the current tax year) in its holding period

when the foreign corporation was a PFIC are not included

in income, but are subject to the separate tax and interest

charge set forth in section 1291(c).

See the instructions for Part V, later.

Exempt organizations. If a shareholder of a PFIC is a

tax-exempt organization, the rules of section 1291 will

apply only if a dividend from the PFIC would be taxable to

the shareholder under subchapter F.

Coordination of mark-to-market regimes with section

1291. Shareholders of a PFIC that is marked to market

under section 1296 or any other Code provision may be

subject to section 1291 in the first tax year in which the

shareholder marks to market the PFIC stock. See

Regulations sections 1.1291-1(c)(4) and 1.1296-1(i).

Mark-to-Market Election

A shareholder of a PFIC may elect to mark to market the

PFIC stock under section 1296 if the stock is “marketable

stock.” See the instructions for Election C, later, for

information on making this election.

Marketable stock. Marketable stock is:

• PFIC stock that is regularly traded (as defined in

Regulations section 1.1296-2(b)) on:

1. A national securities exchange that is registered

with the Securities and Exchange Commission (SEC),

2. The national market system established under

section 11A of the Securities Exchange Act of 1934, or

Instructions for Form 8621 (Rev. 12-2025)

3. A foreign securities exchange that is regulated or

supervised by a governmental authority of the country in

which the market is located and has the characteristics

described in Regulations section 1.1296-2(c)(1)(ii).

• Stock in certain PFICs described in Regulations section

1.1296-2(d).

For additional information, including special rules for

regulated investment companies (RICs) that own PFIC

stock, see Regulations section 1.1296-1 and 1.1296-2.

Tax Consequences

After a PFIC shareholder elects to mark the stock to

market under section 1296, the shareholder either:

1. Includes in income each year an amount equal to

the excess, if any, of the fair market value of the PFIC

stock as of the close of the tax year over the shareholder's

adjusted basis in such stock; or

2. Is allowed a deduction equal to the lesser of:

a. The excess, if any, of the adjusted basis of the PFIC

stock over its fair market value as of the close of the tax

year; or

b. The excess, if any, of the amount of mark-to-market

gain included in the gross income of the PFIC shareholder

for prior tax years over the amount allowed such PFIC

shareholder as a deduction for a loss with respect to such

stock for prior tax years.

See the instructions for Part II, Election C, and Part IV,

later, for more information, including special rules that may

apply in the year that a mark-to-market election is made.

Basis adjustment. If the stock is held directly, the

shareholder's adjusted basis in the PFIC stock is

increased by the amount included in income and

decreased by any deductions allowed. If the stock is

owned indirectly through foreign entities, see Regulations

section 1.1296-1(d)(2).

Additional Information Required

Reportable transaction disclosure statement. A 10%

shareholder (by vote or value) of a QEF may also be

required to file Form 8886 if the QEF is considered to have

participated in a reportable transaction pursuant to

Regulations section 1.6011-4(c)(3)(i)(G). See Form 8886,

Reportable Transaction Disclosure Statement, and

Regulations section 1.6011-4 for additional information.

Rounding Off to Whole Dollars

The shareholder may enter decimal points and cents

when completing Form 8621. However, the shareholder

should consider rounding off cents to whole dollars on

Form 8621 because it may make completing the form

easier. The shareholder must either round off all amounts

on Form 8621 to whole dollars or use cents for all

amounts. To round, drop amounts under 50 cents and

increase amounts from 50 to 99 cents to the next dollar.

For example, $8.40 rounds to $8 and $8.50 rounds to $9.

If two or more amounts must be added to figure the

amount to enter on a line, include cents when adding the

amounts and round off only the total.

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Specific Instructions

Important: All line references to Form 1120 and Form

1040 are to the 2025 forms. Other entities should use the

comparable line on their tax return.

Excepted Specified Foreign Financial

Assets Reported

Check this box only if the Form 8621 filer also files Form

8938, Statement of Specified Foreign Financial Assets, for

the tax year and includes this form in the total number of

Forms 8621 reported on line 4 of Part IV, Excepted

Specified Foreign Financial Assets, of Form 8938. For

more information, see the Instructions for Form 8938,

available at IRS.gov/Form8938, generally, and in

particular, Duplicative Reporting and the specific

instructions for Part IV, Excepted Specified Foreign

Financial Assets.

Election To Be Treated as a Qualifying

Insurance Corporation

Who may make the election. A U.S. person that is a

shareholder (or holds an option to purchase stock) of a

corporation that fails to qualify as a qualifying insurance

corporation (QIC) (as defined in section 1297(f)(1)) solely

because its applicable insurance liabilities make up 25%

or less of its total assets may elect to treat the stock as

stock of a qualifying insurance corporation under the

alternative facts and circumstances test set forth in

section 1297(f)(2) and Regulations section 1.1297-4(d) if:

1. The foreign corporation’s applicable insurance

liabilities make up at least 10% of its total assets; and

2. Based on the applicable facts and circumstances,

the foreign corporation is predominantly engaged in an

insurance business, and its failure to satisfy the 25%

threshold is due solely to runoff-related or rating-related

circumstances involving such insurance business.

The U.S. shareholder may make the election under

section 1297(f)(2) for its tax year if:

• The foreign corporation directly provides the

shareholder a statement, signed by a responsible officer

of the foreign corporation or an authorized representative

of the foreign corporation, that the foreign corporation

satisfied the requirements of section 1297(f)(2) and

Regulations section 1.1297-4(d)(1) during the foreign

corporation's applicable reporting period (as defined in

Regulations section 1.1297-4(f)(4)). Specifically, if the

foreign corporation failed to qualify as a QIC under section

1297(f)(1) solely because the ratio of applicable insurance

liabilities to total assets for the tax year is 25% or less, the

statement must (1) indicate that the ratio was at least

10%, along with a calculation of the ratio (with the

resultant ratio double underlined); (2) include a statement

indicating whether the failure to satisfy the 25% test was

the result of runoff-related or rating-related circumstances,

along with a brief description of those circumstances; and

(3) include information that establishes that the foreign

corporation has met the “predominantly engaged in an

insurance business” requirement described in Regulations

section 1.1297-4(d)(2).

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• The foreign corporation (or its foreign parent

corporation on its behalf) makes a publicly available

statement (such as in a public filing, disclosure statement,

or other notice provided to U.S. persons that are

shareholders of the foreign corporation) that it satisfied the

requirements of section 1297(f)(2) and Regulations

section 1.1297-4(d)(1) during the foreign corporation's

applicable reporting period (as defined in Regulations

section 1.1297-4(f)(4)). This publicly available statement

must include the same three items noted in the first

bulleted item above. However, a shareholder may not rely

upon the foreign corporation’s statement described in this

bullet if the U.S. person knows or has reason to know

based upon reasonably accessible information that the

statement was incorrect.

Note: The final regulations do not require the U.S. person

to attach a copy of either of the above statements to Form

8621. See Regulations section 1.1297-4(d)(5).

When to make the election. Generally, the shareholder

must make this election by the due date, including

extensions, of the U.S. person’s tax return for the tax year

for which the taxpayer is relying on the alternative facts

and circumstances test within the meaning of section

1297(f)(2) and Regulations section 1.1297-4(d) to meet

the definition of a qualifying insurance corporation. A U.S.

person can attach the Form 8621 to an amended return

for the tax year of the U.S. person to which the election

relates if the U.S. person can demonstrate that the reason

for not filing the form with its original return was due to

reasonable cause.

How to make the election. Follow these steps to make

the election.

1. Check the box on page 1 of Form 8621.

2. Provide the identifying information for the U.S.

person and the foreign corporation (Name, Address,

Identifying Number (if any)) only. You do not have to

complete any other part of the Form 8621 if you are only

filing the form to make this election.

Deemed election for publicly traded companies. A

U.S. person who owns publicly traded stock in a foreign

corporation will be deemed to make the election under

section 1297(f)(2) with respect to the foreign corporation

and its subsidiaries if the following requirements are

satisfied.

• The stock of the foreign corporation that is owned by

the U.S. person (including stock owned indirectly) has a

value of $25,000 or less ($50,000 or less in the case of a

joint return) on the last day of the U.S. person's tax year

and on any day during the tax year on which the U.S.

person disposes of stock of the foreign corporation; and

• If the U.S. person owns stock of the foreign corporation

indirectly through a domestic partnership, domestic trust,

domestic estate, or S corporation (a domestic

pass-through entity), the stock of the foreign corporation

that is owned by the domestic pass-through entity has a

value of $25,000 or less on the last day of the tax year of

the domestic pass-through entity that ends with or within

the U.S. person's tax year and on any day during the tax

year of the domestic pass-through entity on which it

disposes of stock of the foreign corporation.

Instructions for Form 8621 (Rev. 12-2025)

For these purposes, stock is publicly traded if it would

be treated as marketable stock within the meaning of

section 1296(e) and Regulations section 1.1296-2

(without regard to Regulations section 1.1296-2(d)) if the

election under section 1297(f)(2) is not made.

Address and Identifying Number

Address. Include the suite, room, or other unit number

after the street address. If the post office does not deliver

mail to the street address and the shareholder has a P.O.

box, enter the box number instead.

Identifying number. Individuals should enter a social

security number or a taxpayer identification number

issued by the IRS. All other entities should enter an

employer identification number (EIN).

Reference ID number. A reference ID number is

required in the applicable entry space above Part I of the

form only in cases where no EIN was entered for the PFIC,

QEF, or QIC. However, filers are permitted to enter both an

EIN and a reference ID number. If applicable, enter the

reference ID number (defined below) you have assigned

to the PFIC, QEF, or QIC.

A “reference ID number” is a number established by or

on behalf of the U.S. person identified at the top of page 1

of the form that is assigned to a PFIC, QEF, or QIC with

respect to which Form 8621 reporting is required. These

numbers are used to uniquely identify the PFIC, QEF, or

QIC in order to keep track of the entity from tax year to tax

year. The reference ID number must meet the

requirements set forth below.

Note: Because reference ID numbers are established by

or on the behalf of a U.S. person filing Form 8621, there is

no need to apply to the IRS to request a reference ID

number or for permission to use these numbers.

Note: In general, the reference ID number assigned to a

PFIC, QEF, or QIC on Form 8621 has relevance only to

Form 8621 and should not be used with respect to the

PFIC, QEF, or QIC on other IRS forms.

Requirements. The reference ID number must be

alphanumeric (defined below), and no special characters

or spaces are permitted. The length of a given reference

ID number is limited to 50 characters.

For these purposes, the term “alphanumeric” means

the entry can be alphabetical, numeric, or any

combination of the two.

The same reference ID number must be used

consistently from tax year to tax year with respect to a

given PFIC, QEF, or QIC. If for any reason a reference ID

number falls out of use (for example, the PFIC, QEF, or

QIC no longer exists due to disposition or liquidation), the

reference ID number used for that PFIC, QEF, or QIC

cannot be used again for another PFIC, QEF, or QIC for

purposes of Form 8621 reporting.

There are some situations that warrant correlation of a

new reference ID number with a previous reference ID

number when assigning a new reference ID number to a

PFIC, QEF, or QIC. For example:

• In the case of a merger or acquisition, a Form 8621 filer

must use a reference ID number that correlates the

Instructions for Form 8621 (Rev. 12-2025)

previous reference ID number with the new reference ID

number assigned to the PFIC, QEF, or QIC.

• In the case of an entity classification election that is

made on behalf of a PFIC, QEF, or QIC on Form 8832,

Regulations section 301.6109-1(b)(2)(v) requires the

PFIC, QEF, or QIC to have an EIN for this election. For the

first year that Form 8621 is filed after an entity

classification election is made on behalf of the PFIC, QEF,

or QIC on Form 8832, the new EIN must be entered in the

applicable entry space above Part I of Form 8621 and the

old reference ID number must be entered in the applicable

entry space just below. In subsequent years, the Form

8621 filer may continue to enter both the EIN and the

reference ID number, but must enter at least the EIN.

You must correlate the reference ID numbers as

follows: New reference ID number [space] Old reference

ID number. If there is more than one old reference ID

number, you must enter a space between each such

number. As indicated above, the length of a given

reference ID number is limited to 50 characters and each

number must be alphanumeric and no special characters

are permitted.

Note: This correlation requirement applies only to the first

year the new reference ID number is used.

Part I. Summary of Annual

Information

Who Must Complete Part I

In general, all shareholders required to file Form 8621

under section 1298(f) and the regulations thereunder must

complete Part I. However, a shareholder of a PFIC that is

marked to market under a Code provision other than

section 1296 (such as section 475) is not required to

complete Part I unless it is subject to section 1291 with

respect to the PFIC pursuant to Regulations section

1.1291-1(c)(4)(ii). See T.D. 9806.

Shareholders filing a joint return may file a single Form

8621 with respect to a single PFIC in which each joint filer

owns an interest.

Shareholders that are the first U.S. person in the

chain of ownership. Regulations section 1.1298-1

generally requires a U.S. person that is at the lowest tier in

a chain of ownership (that is, the first U.S. person in the

chain of ownership) and that is a shareholder (including

an indirect shareholder) of a PFIC to complete Part I for

each PFIC owned by that shareholder during the

shareholder’s tax year.

Specific filing requirements apply with respect to

Domestic grantor trusts, as described later in these

Instructions.

Exceptions to these filing requirements are described

later under Exceptions to Filing Part I.

Shareholders that are not the first U.S. person in the

chain of ownership. In general, an indirect shareholder

that is not the first U.S. person in the chain of ownership is

not required to complete Part I unless the indirect

shareholder:

• Is treated as receiving an excess distribution from the

PFIC;

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• Is treated as recognizing gain that is treated as an

excess distribution as a result of a disposition of the PFIC;

• Is required to include an amount in income under

section 1293(a) with respect to the PFIC, unless another

shareholder through which the indirect shareholder owns

the PFIC files under section 1298(f) with respect to the

PFIC and no other exception applies;

• Is required to include an amount in income under

section 1296(a) with respect to the PFIC, unless another

shareholder through which the indirect shareholder owns

the PFIC files under section 1298(f) with respect to the

PFIC; or

• Is required to report the status of a section 1294

election with respect to the PFIC.

See Regulations section 1.1298-1(b)(2) for further

information.

to complete Part I with respect to a specific section 1291

fund if the shareholder meets the $25,000 exception on

the last day of the shareholder’s tax year and the

shareholder does not receive an excess distribution from,

or recognize gain on the sale or disposition of the stock of,

the section 1291 fund. For purposes of determining

whether a shareholder satisfies the $25,000 threshold, the

shareholder takes into account all PFIC stock (QEFs,

section 1291 funds, and PFIC stock subject to a section

1296 mark-to-market election) owned directly or indirectly

other than PFIC stock owned through another U.S. person

or PFIC stock owned through another PFIC. Shareholders

filing a joint return have a combined threshold of $50,000

instead of $25,000 for purposes of this exception.

For more information, see Regulations section

1.1298-1(c)(2).

Domestic grantor trusts. In general, a U.S. grantor of a

domestic grantor trust that owns an interest in a PFIC

(directly or indirectly) through one or more foreign entities

must complete Part I with respect to that PFIC interest.

See Regulations sections 1.1291-1(b)(8)(iii)(D) and

1.1298-1(b)(1)(iii). In those circumstances, a domestic

grantor trust is not required to complete Part I with respect

to the stock of the PFIC that is owned by the grantor. For

certain exceptions, see Regulations section 1.1298-1(b)

(3)(i).

Exception if the value of shareholder’s indirect PFIC

stock is $5,000 or less. A shareholder is not required to

complete Part I with respect to indirect ownership of a

specific section 1291 fund if the shareholder meets the

$5,000 exception with respect to the section 1291 fund on

the last day of the shareholder’s tax year and the

shareholder does not receive an excess distribution from,

or recognize gain on the sale or disposition of the stock of,

the section 1291 fund. For purposes of determining

whether a shareholder satisfies the $5,000 threshold, the

shareholder takes into account only the value of the

shareholder’s proportionate share of the section 1291

fund.

For more information, see Regulations section

1.1298-1(c)(2).

Exceptions To Filing Part I

A shareholder is exempt from completing Part I if it meets

one of the exceptions described below.

Special rules for estates and trusts. Certain U.S.

grantors and beneficiaries of estates and trusts may

qualify for an exception to filing Part I.

• A U.S. grantor of a domestic grantor trust is not required

to complete Part I if the trust is a domestic liquidating trust

or a widely held fixed investment trust, as described in

Regulations section 1.1298-1(b)(3)(i). In these

circumstances, the domestic grantor trust is required to

complete Part I.

• In certain situations, a shareholder who is a member or

beneficiary of (or participant in) an arrangement treated as

a foreign pension fund under a U.S. income tax treaty that

owns an interest in a PFIC is not required to complete Part

I with respect to the PFIC. See Regulations section

1.1298-1(c)(4).

• A U.S. beneficiary of a foreign nongrantor trust or

foreign estate is not required to complete Part I with

respect to the stock of the PFIC that is owned by the trust

or estate unless it has made a QEF or section 1296

mark-to-market election, received an excess distribution,

or recognized gain treated as an excess distribution with

respect to the stock of the PFIC. See Regulations section

1.1298-1(b)(3)(ii).

Exempt organizations. In general, if a shareholder of a

PFIC is a tax-exempt organization, the shareholder is

required to complete Part I only if income derived with

respect to the PFIC stock would be taxable to the

shareholder under subchapter F. See Regulations section

1.1298-1(c)(1).

Line Instructions

Line 1. Describe each class of shares held by the

shareholder.

Line 2. Provide the date during the tax year that the

shares were acquired, if applicable.

Line 3. List the number of shares held at the end of the

tax year.

Line 4. Indicate the value of the shares held at the end of

the tax year. Shareholders may rely upon periodic account

statements provided at least annually to determine the

value of a PFIC unless the shareholder has actual

knowledge or reason to know based on readily accessible

information that the statements do not reflect a reasonable

estimate of the PFIC’s value.

Line 5. Indicate the type of PFIC and the amount of any

excess distribution or gain treated as an excess

distribution under section 1291, inclusion under section

1293, and inclusion or deduction under section 1296.

Note: In cases in which a shareholder’s ownership

interest in a PFIC is not denominated in shares, the

shareholder must provide the information for lines 1

through 4 based on its form of ownership in the PFIC.

Exception if aggregate value of shareholder’s PFIC

stock is $25,000 or less. A shareholder is not required

6

Instructions for Form 8621 (Rev. 12-2025)

Part II. Elections

A. Election To Treat the PFIC as a QEF (Section

1295 Election)

Who May Make the Election

Generally, a U.S. person that owns stock in a PFIC,

directly or indirectly, may make Election A to treat the PFIC

as a QEF.

Note: A separate election must be made for each PFIC

that the shareholder wants to treat as a QEF.

Exception. A tax-exempt organization that is not taxable

under section 1291 may not make the election. In

addition, a tax-exempt organization that is not taxable

under section 1291 is not subject to a QEF election made

by a pass-through entity.

Chain of ownership. In a chain of ownership, only the

first U.S. person that is a direct or indirect shareholder of

the PFIC may make the election.

Pass-through entities. A QEF election made by a

domestic partnership, S corporation, or estate is made in

the pass-through entity's capacity as a shareholder of a

PFIC. The entity will include the QEF earnings as income

for the year in which the PFIC's tax year ends. The interest

holder in the pass-through entity takes the income into

account under the rules applicable to inclusions of income

from the pass-through entity.

Affiliated groups. The common parent of an affiliated

group of corporations that joins in filing a consolidated

income tax return makes the QEF election for all members

of the affiliated group that are shareholders in the PFIC.

An election by a common parent is effective for all

members of the group that own stock in the PFIC at the

time the election is made or any time thereafter.

For more information on who may make the election,

see Regulations section 1.1295-1(d).

When To Make the Election

Generally, a shareholder must make the election to be

treated as a QEF by the due date, including extensions,

for filing the shareholder's income tax return for the first

tax year to which the election will apply (the “election due

date”). See Retroactive election, below, for exceptions.

The foreign corporation will be treated as a QEF with

respect to the shareholder for the tax year in which the

election is made and for each subsequent tax year of the

foreign corporation ending with or within a tax year of the

shareholder for which the election is effective.

Retroactive election. A shareholder may make a QEF

election for a tax year after the election due date (a

retroactive election) only if:

• The shareholder has preserved its right to make a

retroactive election under the Protective statement regime

(described below), or

• The shareholder obtains the permission of the IRS to

make a retroactive election under the Consent regime

(described later).

Instructions for Form 8621 (Rev. 12-2025)

Protective statement regime. Under the protective

statement regime, a shareholder may preserve the ability

to make a retroactive election if the shareholder:

1. Reasonably believed, as of the due date for making

the QEF election, that the foreign corporation was not a

PFIC for its tax year that ended during that year

(retroactive election year);

2. Filed a Protective Statement (see below) with

respect to the foreign corporation, applicable to the

retroactive election year, in which the shareholder

describes the basis for its reasonable belief;

3. Extended, in the Protective Statement, the periods

of limitations on the assessment of taxes under the PFIC

rules for all tax years to which the protective statement

applies; and

4. Complied with the other terms and conditions of the

protective statements.

The Protective Statement must be attached to the

shareholder's tax return for the shareholder's first tax year

to which the statement will apply. For required content of

the statement and other information, see Regulations

section 1.1295-3(c).

Consent regime. Under the consent regime, a

shareholder that has not satisfied the requirements of the

protective regime may request that the IRS permit a

retroactive election. The consent regime applies only if:

1. The shareholder reasonably relied on tax advice of

a competent and qualified tax professional;

2. The interest of the U.S. Government will not be

prejudiced if the consent is granted;

3. The shareholder requests consent before the PFIC

status issue is raised on audit; and

4. The shareholder satisfies the procedural

requirements under Regulations section 1.1295-3(f)(4).

For more information on making a retroactive election,

see Regulations section 1.1295-3.

Special Rules

For rules relating to the invalidation, termination, or

revocation of a section 1295 election, see Regulations

section 1.1295-1(i). Also, see Regulations section

1.1295-1(c)(2) for rules relating to the years to which a

section 1295 election applies.

How To Make the Election

For the tax year in which the section 1295 election is

made, the shareholder must do the following.

1. Check box A in Part II of Form 8621.

2. Complete the applicable lines of Part III. Include the

information provided in the PFIC Annual Information

Statement, Annual Intermediary Statement, or a

Combined statement (see below) received from the PFIC.

3. Attach Form 8621 to a timely filed tax return (or, if

applicable, partnership or exempt organization return).

7

For each subsequent tax year in which the election

applies and the corporation is treated as a QEF, the

shareholder must:

1. Complete the applicable lines of Part III, and

2. Attach Form 8621 to a timely filed tax return (or, if

applicable, a partnership or exempt organization return).

Annual Election Requirements of the PFIC or

Intermediary

If a U.S. partnership is a shareholder of a QEF, the

election is made at the partner level.

Special Rules

• If this election is made, interest will be imposed on the

amount of the deferred tax. This interest must be paid on

the termination of the election (see the instructions for Part

VI, line 24, later).

• The election cannot be made for any earnings on

shares disposed of during the tax year or for a tax year

that any portion of the shareholder's pro rata share of the

fund's earnings is included in income under section 951

(relating to CFCs).

PFIC Annual Information Statement. For each year of

the PFIC ending in a tax year of a shareholder to which

the QEF election applies, the PFIC must provide the

shareholders with a PFIC Annual Information Statement.

The statement must contain certain information, including:

1. The shareholder's pro rata share of the PFIC's

ordinary earnings and net capital gain for that tax year, or

2. Sufficient information to enable the shareholder to

calculate its pro rata share of the PFIC's ordinary earnings

and net capital gain for that tax year.

When To Make the Election

For other information required to be included in the

PFIC Annual Information Statement, see Regulations

section 1.1295-1(g).

How To Make the Election

Annual Intermediary Statement. If the shareholder

holds stock in a PFIC through an intermediary, an Annual

Intermediary Statement may be issued in lieu of the PFIC

Annual Information Statement. For the definition of an

“intermediary,” see Regulations section 1.1295-1(j). For

details on the information that should be included in the

Annual Intermediary Statement, see Regulations section

1.1295-1(g)(3).

For more information on making Election B, see

Temporary Regulations section 1.1294-1T.

Combined statements. A PFIC that owns directly or

indirectly any shares of stock in one or more PFICs may

provide its shareholders with a PFIC Annual Information

Statement in which it combines its own required

information and representations with the information and

representations of any lower-tier PFIC. Similarly, an

intermediary through which a shareholder indirectly holds

stock in more than one PFIC may provide the shareholder

with a combined Annual Intermediary Statement. For

more information, see Regulations section 1.1295-1(g)(4).

Documentation. For all tax years subject to the section

1295 election, the shareholder must keep copies of all

Forms 8621, attachments, and PFIC Annual Information

Statements or Annual Intermediary Statements. Failure to

produce these documents at the request of the IRS may

result in invalidation or termination of the section 1295

election. See Regulations section 1.1295-1(f)(2)(ii). In rare

and unusual circumstances, the IRS will consider requests

for alternative documentation to verify the ordinary

earnings and net capital gain of the PFIC. For more

information, see Regulations section 1.1295-1(g)(2).

B. Election To Extend Time for Payment of Tax

Who May Make the Election

A shareholder of a QEF may make Election B to extend

the time for payment of the tax on its share of the

undistributed earnings of the fund for the current tax year.

8

Generally, this election must be made by the due date,

including extensions, of the shareholder's tax return for the

tax year for which the shareholder reports the income

related to the deferred tax.

Take these steps to make this election.

1. Check box B in Part II.

2. Complete lines 8a through 9c of Part III.

Note: The temporary regulations instruct taxpayers to file

a duplicate copy of the election with the Philadelphia

service center, in addition to filing the election with their

returns for the year. Taxpayers may, but are not required

to, file the duplicate copy.

See Part VI for annual reporting requirements for

outstanding section 1294 elections.

C. Election To Mark to Market PFIC Stock

(Section 1296 Election)

Who May Make the Election

Generally, an election to mark to market PFIC stock under

section 1296 may be made by:

• A U.S. person who owns (or is treated as owning)

Marketable stock (defined earlier) in a PFIC at the close of

such person's tax year, or

• A RIC that meets the requirements of section 1296(e)

(2).

For more information, see section 1296 and

Regulations section 1.1296-1. See sections 1296(f) and

(g) and Regulations sections 1.1296-1(e) and (h)(1)(ii) for

information regarding stock owned through certain foreign

entities.

When To Make the Election

This election must be made on or before the due date

(including extensions) of the U.S. person's income tax

return for the tax year in which the stock is marked to

market under section 1296. A section 1296 election by a

Instructions for Form 8621 (Rev. 12-2025)

CFC is made by its controlling domestic shareholders (as

defined in Regulations section 1.964-1(c)(5)). For more

information, see Regulations section 1.1296-1(h)(1)(ii).

Once made, the election applies to all subsequent tax

years unless the election is revoked or terminated

pursuant to Regulations section 1.1296-1(h)(3).

How To Make the Election

Take these steps to make this election.

1. Check box C in Part II.

2. Complete either (a) Part V to calculate the amount

due under section 1291 (when required, as generally

described in the next paragraph), or (b) Part IV to

calculate the gain or loss on the stock in all other cases.

Coordination of Election C with section 1291 for first

year of election. In general, when a shareholder makes

a mark-to-market election for PFIC stock in a year other

than the first year in which the shareholder holds stock in

the PFIC and no QEF election is in effect, the PFIC stock

is treated as sold at fair market value on the last day of the

tax year for which the election is made, and the gain is

treated as an excess distribution subject to section 1291.

In addition, any distributions made during the year with

respect to the PFIC stock are subject to section 1291. See

section 1296(j) and Regulations section 1.1296-1(i).

D. Deemed Sale Election in Connection With a

QEF Election

Who May Make the Election

This is a deemed sale election under section 1291(d)(2)

(A). This election may be made by a U.S. person that

elects to treat a PFIC as a QEF for a foreign corporation's

tax year following its first tax year as a PFIC included in

the shareholder's holding period (an unpedigreed QEF). A

shareholder making this election is deemed to have sold

the PFIC stock as of the first day of the PFIC's first tax

year as a QEF (the qualification date) for its fair market

value.

Special Rules

For purposes of this election, the following apply.

• The gain from the deemed sale is taxed as an excess

distribution received on the qualification date.

• The basis of the shareholder’s PFIC stock held directly,

or the stock or other property owned directly by the

shareholder through which ownership of the PFIC is

attributed to the shareholder, is increased by the gain

recognized. The manner in which the basis adjustment is

made depends on whether the shareholder is a direct or

indirect shareholder. See Regulations section

1.1291-10(f).

• Solely for purposes of applying the PFIC rules, the

shareholder's holding period of the stock begins on the

qualification date.

• The election may be made for stock on which the

shareholder will realize a loss, but that loss cannot be

recognized. In addition, there is no basis adjustment for a

loss.

Instructions for Form 8621 (Rev. 12-2025)

• After the deemed sale, the PFIC becomes a pedigreed

QEF with respect to the shareholder.

When To Make the Election

This election must be made by the due date, including

extensions, of the shareholder's original tax return (or by

filing an amended return within 3 years of the due date of

the original return) for the tax year that includes the

qualification date.

How To Make the Election

Take these steps to make this election.

1. Check box D in Part II.

2. Enter the gain or loss on line 15f of Part V.

3. If a gain is entered, complete line 16 to report the

tax and interest due on the excess distribution.

For more information regarding making Election D, see

Regulations section 1.1291-10.

E. Deemed Dividend Election in Connection

With a QEF Election

Who May Make the Election

This is a deemed dividend election under section 1291(d)

(2)(B). This election may be made by a U.S. person that

elects to treat a PFIC that is also a CFC as a QEF for the

foreign corporation's tax year following its first tax year as

a PFIC included in the shareholder's holding period (an

unpedigreed QEF).

A shareholder making this election is treated as

receiving a dividend equal to its pro rata share of the

post-1986 earnings and profits (defined below in Special

Rules) of the PFIC on the qualification date (defined under

the instructions for Election D, earlier). The deemed

dividend is taxed as an excess distribution, allocated only

to the days in the shareholder's holding period during

which the foreign corporation qualified as a PFIC. For this

purpose, the shareholder's holding period ends on the day

before the qualification date.

Special Rules

For purposes of this election, the following apply.

• The term “post-1986 earnings and profits” means the

undistributed earnings and profits of the PFIC (as of the

day before the qualification date) accumulated and not

distributed in tax years beginning after 1986 during which

the foreign corporation was a PFIC and while the

shareholder held the stock (but without regard to whether

the earnings relate to a period in which the PFIC was a

CFC).

• The basis of the shareholder's PFIC stock held directly,

or the stock or other property owned directly by the

shareholder through which ownership of the PFIC is

attributed to the shareholder, is increased by the amount

of the deemed dividend. The manner in which the basis

adjustment is made depends on whether the shareholder

is a direct or indirect shareholder. See Regulations section

1.1291-9(f).

9

• Solely for purposes of applying the PFIC rules, the

shareholder's holding period begins on the qualification

date.

When To Make the Election

This election must be made by the due date (including

extensions) of the shareholder's original tax return (or by

filing an amended return within 3 years of the due date of

the original return) for the tax year that includes the

qualification date.

How To Make the Election

Take these steps to make this election.

1. Check box E in Part II.

2. Enter the dividend on line 15e(2) of Part V as an

excess distribution.

3. Complete line 16 to figure the tax and interest due

on the excess distribution.

Attachments. The shareholder must attach a statement

to Form 8621 that demonstrates the calculation of its pro

rata share of the post-1986 earnings and profits of the

PFIC that are treated as distributed to the shareholder on

the qualification date. The post-1986 earnings and profits

may be reduced (but not below zero) by the amount that

the shareholder satisfactorily demonstrates was

previously included in its income or in the income of

another U.S. person. The shareholder demonstrates this

by including in the statement mentioned above the

following information.

• The name, address, and identifying number of the U.S.

person and the amount that was included in income.

• The tax year in which the amount was previously

included in income;

• The provision of law under which the amount was

previously included in income;

• A description of the transaction in which the

shareholder acquired the stock of the PFIC from the other

U.S. person; and

• The provision of law under which the shareholder's

holding period includes the holding period of the other

U.S. person.

For more information on making Election E, see

Regulations section 1.1291-9.

F. Deemed Sale Election With Respect to a

Former PFIC or “Section 1297(e) PFIC”

Who May Make the Election

This is a deemed sale election under section 1298(b)(1)

and Regulations section 1.1297-3(b) or 1.1298-3(b). This

election may be made by:

• A U.S. person that is a shareholder of a foreign

corporation that no longer qualifies as a PFIC under either

the income or asset test of section 1297(a), or

• A U.S. shareholder (as defined in section 951(b)) that

owns stock in a foreign corporation that is a CFC and a

PFIC, but that is not treated as a PFIC with respect to the

U.S. shareholder under section 1297(d).

10

Such persons may elect to treat the stock of the foreign

corporation as sold for its fair market value on the last day

of the last tax year of the foreign corporation in which it

was treated as a PFIC (termination date) or the first day on

which the qualified portion of the shareholder’s holding

period in the section 1297(e) PFIC begins (qualification

date), as applicable.

Special Rules

• The gain from the deemed sale is taxed as an excess

distribution.

• The basis of the shareholder’s PFIC stock held directly,

or the stock or other property owned directly by the

shareholder through which ownership of the PFIC is

attributed to the shareholder, is increased by the amount

of the excess distribution taxed to the shareholder making

Election F. The manner in which the basis adjustment is

made depends on whether the shareholder is a direct or

indirect shareholder. See Regulations sections 1.12973(b)(5) and 1.1298-3(b)(5).

• Solely for purposes of applying the PFIC rules, the new

holding period of the stock begins on the date after the

termination date or on the qualification date, as

applicable.

• Election F may be made for stock on which there would

be a loss, but the loss is not recognized.

For more information on making this election, see

Regulations sections 1.1297-3(b) (section 1297(e) PFIC)

and 1.1298-3(b) (former PFIC).

When To Make the Election

This election must be made by the due date of the

shareholder’s original tax return (or by filing an amended

return within 3 years of the due date, as extended under

section 6081, of the original return) for the tax year that

includes, as appropriate, either the termination date or

qualification date. However, see Form 8621-A, Return by a

Shareholder Making Certain Late Elections To End

Treatment as a Passive Foreign Investment Company,

available at IRS.gov/Form8621A, (and Regulations

sections 1.1297-3(e) and 1.1298-3(e)) if the 3-year period

has expired.

How To Make the Election

Take these steps to make this election.

1. Check box F in Part II.

2. Enter the gain or loss on line 15f of Part V. If a gain,

complete the rest of Part V.

G. Deemed Dividend Election With Respect to a

“Section 1297(e) PFIC”

Who May Make the Election

This is a deemed dividend election under section 1298(b)

(1) and Regulations section 1.1297-3(c). This election

may be made by a shareholder that is a U.S. shareholder

(as defined in section 951(b)) of a foreign corporation that

is a CFC and a PFIC, but that is not treated as a PFIC with

respect to the U.S. shareholder under section 1297(d).

Instructions for Form 8621 (Rev. 12-2025)

Special Rules

A shareholder making this election is treated as receiving

a dividend of its pro rata share of the post-1986 earnings

and profits (defined later in Attachments) of the section

1297(e) PFIC on the CFC qualification date (as defined in

Regulations section 1.1297-3(d)). The deemed dividend is

taxed under section 1291 as an excess distribution,

allocated only to the days in the shareholder’s holding

period during which the foreign corporation qualified as a

PFIC. For this purpose, the shareholder’s holding period

ends on the day before the CFC qualification date. After

the deemed dividend election, the shareholder’s stock is

not treated as stock in a PFIC.

For purposes of this election, the following rules apply.

• The basis of the shareholder’s PFIC stock held directly,

or the stock or other property owned directly by the

shareholder through which ownership of the PFIC is

attributed to the shareholder, is increased by the amount

of the deemed dividend. The manner in which the basis

adjustment is made depends on whether the shareholder

is a direct or indirect shareholder (as defined earlier). See

Regulations section 1.1297-3(c)(6).

• Solely for purposes of applying the PFIC rules, the

shareholder’s new holding period begins on the CFC

qualification date.

When To Make the Election

Make this election by the due date of the shareholder’s

original return (or by filing an amended return within 3

years of the due date, as extended under section 6081, of

the original return) for the tax year that includes the first

day on which the qualified portion of the shareholder’s

holding period in the PFIC begins, as determined under

section 1297(d). However, see Form 8621-A (and

Regulations section 1.1297-3(e)) if the 3-year period has

expired.

How To Make the Election

Take these steps to make this election.

1. Check box G in Part II.

2. Enter the excess distribution on line 15e(2) of Part

V.

3. If the excess distribution is greater than zero,

complete line 16 to figure the tax and interest due on the

excess distribution.

4. Attach to Form 8621 the information specified

below.

Attachments

The shareholder must attach a statement to Form 8621

that shows the calculation of its pro rata share of the

post-1986 earnings and profits of the section 1297(e)

PFIC (as defined in Regulations section 1.1291-9(j)(2)(v))

that is treated as distributed to the shareholder on the

CFC qualification date.

• The CFC qualification date, as defined in Regulations

section 1.1297-3(d), for the Section 1297(e) PFIC.

Instructions for Form 8621 (Rev. 12-2025)

• The beginning and ending dates of the tax year of the

shareholder in which the CFC qualification date falls (that

is, the election year).

• The shareholder’s pro rata share of the post-1986

earnings and profits of the Section 1297(e) PFIC that is

treated as distributed to the shareholder on the CFC

qualification date, including a schedule that shows the

calculation of this amount as required under Regulations

section 1.1297-3(c)(5)(ii). In addition, if the shareholder

filed a Form 5471 for the Section 1297(e) PFIC for the

election year, attach Schedule J (Form 5471).

The post-1986 earnings and profits may be reduced

(but not below zero) by the amount that the shareholder

satisfactorily shows was previously included in its income

or in the income of another U.S. person. The shareholder

shows this by including in the statement mentioned above

the following information.

• The name, address, and identifying number of the U.S.

person and the amount that was included in income.

• A description of the transaction in which the

shareholder acquired the stock of the Section 1297(e)

PFIC from the other U.S. person.

• The tax year in which the amount was previously

included in income.

• The provision of law under which the shareholder's

holding period includes the holding period of the other

U.S. person.

For more information on making Election G, see

Regulations section 1.1297-3(c).

H. Deemed Dividend Election With Respect to a

Former PFIC

Who May Make the Election

This is a deemed dividend election under section 1298(b)

(1) and Regulations section 1.1298-3(c). This election

may be made by a shareholder of a foreign corporation

that no longer qualifies as a PFIC under either the income

or asset test of section 1297(a) if the foreign corporation

was a CFC during its last tax year as a PFIC.

Special Rules

A shareholder making this election is treated as receiving

a dividend of its pro rata share of the post-1986 earnings

and profits (defined later in Attachments) of the former

PFIC on the termination date (as defined in Regulations

section 1.1298-3(d)). The deemed dividend is taxed under

section 1291 as an excess distribution, allocated only to

the days in the shareholder’s holding period during which

the foreign corporation qualified as a PFIC. For this

purpose, the shareholder's holding period ends on the

termination date. After the deemed dividend election, the

shareholder’s stock is not treated as stock in a PFIC.

For purposes of this election, the following rules apply.

• The basis of the shareholder’s PFIC stock held directly,

or the stock or other property owned directly by the

shareholder through which ownership of the PFIC is

attributed to the shareholder, is increased by the amount

of the deemed dividend. The manner in which the basis

adjustment is made depends on whether the shareholder

11

is a direct or indirect shareholder (as defined earlier). See

Regulations section 1.1298-3(c)(6).

• Solely for purposes of applying the PFIC rules, the

shareholder’s new holding period begins on the day

following the termination date.

When To Make the Election

This election must be made by the due date of the

shareholder’s original return (or by filing an amended

return within 3 years of the due date, as extended under

section 6081, of the original return) for the tax year that

includes the first day on which the qualified portion of the

shareholder’s holding period in the PFIC begins, as

determined under section 1297(d). However, see Form

8621-A (and Regulations section 1.1298-3(e)) if the

3-year period has expired.

How To Make the Election

Take these steps to make this election.

1. Check box H in Part II.

2. Enter the excess distribution on line 15e(2) of Part

V.

3. If the excess distribution is greater than zero,

complete line 16 to figure the tax and interest due on the

excess distribution.

4. Attach to Form 8621 the information specified

below.

Attachments

The shareholder must attach a statement to Form 8621

that shows the calculation of its pro rata share of the

post-1986 earnings and profits of the former PFIC that is

treated as distributed to the shareholder on the

termination date.

• The termination date, as defined in Regulations section

1.1298-3(d), for the former PFIC.

• The beginning and ending dates of the tax year of the

shareholder in which the termination date falls (that is, the

election year).

• The shareholder’s pro rata share of the post-1986

earnings and profits of the former PFIC that is treated as

distributed to the shareholder on the termination date,

including a schedule that shows the calculation of this

amount as required under Regulations section

1.1298-3(c)(5)(ii). In addition, if the shareholder filed a

Form 5471 for the former PFIC for the election year, attach

Schedule J (Form 5471).

The post-1986 earnings and profits may be reduced

(but not below zero) by the amount that the shareholder

satisfactorily shows was previously included in its income

or in the income of another U.S. person. The shareholder

shows this by including in the statement mentioned above

the following information.

• The name, address, and identifying number of the U.S.

person and the amount that was included in income.

• The tax year in which the amount was previously

included in income.

12

• The provision of law under which the amount was

previously included in income.

• A description of the transaction in which the

shareholder acquired the stock of the former PFIC from

the other U.S. person.

• The provision of law under which the shareholder’s

holding period includes the holding period of the other

U.S. person.

For more information on making Election H, see

Regulations section 1.1298-3(c).

Part III. Income From a QEF

For any tax year in which the foreign corporation is not

treated as a QEF because it is not a PFIC under section

1297(a), the shareholder is not required to complete Part

III. However, the section 1295 election is not terminated. If

the foreign corporation is treated as a PFIC in any

subsequent tax year, the original election continues to

apply and the shareholder must include in Part III its pro

rata share of ordinary earnings and net capital gain and

must also comply with the section 1295 annual reporting

requirements.

All QEF shareholders complete lines 6a through 7c. If

you are making Election B, also complete lines 8a through

9c.

Lines 6 and 7

Lines 6a and 7a. Enter on lines 6a and 7a, respectively,

your pro rata share of the ordinary earnings and net

capital gain of the QEF. The PFIC should provide these

amounts or information that will help you determine your

pro rata share. See Annual Election Requirements of the

PFIC or Intermediary, earlier.

Lines 6b and 7b. Your share of the ordinary earnings

and net capital gain of the QEF is reduced by the amounts

you include in income under section 951 for the tax year

with respect to the QEF. Your share of these amounts may

also be reduced as provided in section 1293(g).

Line 6c. This amount is treated as ordinary income on

your tax return.

For a noncorporate taxpayer, include this amount as

“other income” on Schedule 1 (Form 1040), line 8z, or on

the comparable line of other noncorporate tax returns. For

a corporate taxpayer, include this amount as “other

income” on line 10 of Form 1120, or on the comparable

line of other corporate tax returns.

Line 7c. See the instructions for the Schedule D used for

your tax return. Portions of the net capital gain may have

to be reported on different lines of Schedule D, depending

upon the information provided by the QEF concerning the

section 1(h) categories of net capital gains and amounts

thereof, derived by the QEF. See Regulations section

1.1293-1(a)(2) for three options a QEF may use to report

and calculate capital gain.

Line 8

If you receive a distribution from the QEF during the

current tax year, the distribution is first treated as a

distribution out of the earnings and profits of the QEF

accumulated during the year. If the total amount

Instructions for Form 8621 (Rev. 12-2025)

distributed (line 8b) exceeds the amount included in

income (line 8a), the excess is treated as distributed out of

the most recently accumulated earnings and profits. This

amount is not taxable to you if you can satisfactorily

demonstrate that the excess was previously included in

your income or the income of another U.S. person. This is

demonstrated by attaching a statement to Form 8621 that

includes the information listed under Attachments for

Election E, earlier. If the excess has not been previously

included in your income or the income of another U.S.

person, then the excess is subject to tax according to the

rules of section 301(c).

Line 9

Line 9a. Enter the total tax on your total taxable income

(including your share of undistributed earnings of the

QEF) for the tax year (for example, from Form 1120,

Schedule J, line 11; or Form 1040, line 24).

For this purpose, “undistributed earnings” is the excess,

if any, of the amount included in gross income under

section 1293(a) over the sum of the amount of any

distribution and the portion of the amount attributable to

stock in the QEF that you transferred or otherwise

disposed of before the end of the QEF's tax year.

Line 9b. Calculate your total tax as if your total taxable

income did not include your share of the undistributed

earnings of the QEF (line 8e). Enter this amount on

line 9b.

Line 9c. For corporations, enter this deferred tax on Form

1120, Schedule J, in brackets to the left of the entry space

for line 11. Subtract this deferred tax amount from the sum

of lines 7, 8, and 10, and enter the difference on line 11.

For individuals, enter this deferred tax on Form 1040 in

brackets to the left of the entry space for line 24. Subtract

this deferred tax amount from the sum of lines 22 and 23,

and enter the difference on line 24.

Part IV. Gain or (Loss) From a Section

1296 Mark-to-Market Election

A shareholder that has made a mark-to-market election

under section 1296 with respect to PFIC stock completes

lines 10a through 12 with respect to PFIC stock that the

shareholder holds at the close of its tax year, and lines

13a through 14c, with respect to PFIC stock that it sold or

disposed of during its tax year.

As discussed earlier in Mark-to-Market Election, a

shareholder may be required to complete Part V, rather

than Part IV, in the first year in which a mark-to-market

election is made. See section 1296(j) and Regulations

sections 1.1291-1(c)(4) and 1.1296-1(i).

Lines 10a Through 12

If the fair market value of the PFIC stock as of the close of

the tax year is more than the U.S. person's adjusted basis

in the stock, the excess is treated as ordinary income.

If the adjusted basis of the stock is more than the fair

market value as of the close of the tax year, the excess is

allowed as a deduction, but only to the extent of, the

lesser of:

1. The amount of the excess (line 10c), or

Instructions for Form 8621 (Rev. 12-2025)

2. The Unreversed inclusions (defined below) with

respect to such stock (line 11).

This amount is treated as an ordinary loss and as a

deduction allowable in computing adjusted gross income.

Unreversed inclusions. Unreversed inclusions are the

excess of the amounts that were included in income under

the section 1296 mark-to-market rules for prior tax years

over the amounts allowed as a deduction under the

section 1296 mark-to-market rules for prior tax years. See

section 1296(d) and Regulations section 1.1296-1(a)(3).

Lines 10c and 12. Corporations and individuals should

include the gain or (loss) on the “other income” line of their

tax returns. Other entities should include this amount on

the comparable line of their tax return. However, RICs, for

purposes of section 851(b), should treat amounts included

in income as a dividend.

If a CFC makes a section 1296 mark-to-market election

with respect to a PFIC in which it owns stock, any line 10c

gain is treated as foreign personal holding company

income and any line 12 loss is treated as a deduction that

is allocable to foreign personal holding company income.

Lines 13 Through 14c

Complete lines 13 through 14c if you sold or otherwise

disposed of any section 1296 stock during the tax year.

For purposes of lines 13 through 14c, “section 1296 stock”

is any stock for which the taxpayer has made a

mark-to-market election pursuant to section 1296(a),

which is in effect for the tax year and for which the

coordination rule of Regulations section 1.1296-1(i) does

not apply.

Line 13c. If the fair market value of the stock on the date

of sale or disposition (line 13a) is more than the U.S.

person's adjusted basis in the stock on the date of sale or

disposition (line 13b), the line 13c excess is a gain and is

treated as ordinary income. Corporations and individuals

should include the gain on the “other income” line of their

tax returns. Other entities should include this amount on

the comparable line of their tax return. However, RICs, for

purposes of section 851(b), should treat this amount as a

dividend.

If the adjusted basis of the stock (line 13b) is more than

its fair market value (line 13a), the excess is a loss and is

entered on line 13c as such. Furthermore, the filer must

complete lines 14a and 14b, and, if applicable, line 14c.

Line 14a. Enter any Unreversed inclusions with respect

to the stock (see definition, earlier).

Line 14b. Enter the loss from line 13c, but only to the

extent of unreversed inclusions on line 14a. This loss is

treated as ordinary loss. Corporations and individuals

should include the loss on the “other income” line of their

tax returns. Other entities should include this amount on

the comparable line of their tax return.

Line 14c. Enter the amount by which the loss on line 13c

is more than the unreversed inclusions. This amount is

subject to the rules generally applicable to losses

provided elsewhere in the Code and regulations

thereunder. See Regulations section 1.1296-1(c)(4)(ii).

13

Multiple dispositions. In the case of multiple

dispositions, attach a statement for each disposition using

the same format shown on lines 13 through 14c. Then:

• Enter “multiple” on lines 13a, 13b, and 14a.

• Enter your net ordinary gains on line 13c (do not enter

any net losses on line 13c).

• Enter your net ordinary losses on line 14b.

• Enter your net “other” losses on line 14c.

For more information relating to mark-to-market

elections under section 1296, see Regulations sections

1.1296-1 and 1.1296-2.

Part V. Distributions From and

Dispositions of Stock of a Section

1291 Fund

See Section 1291 Fund, earlier, for the definition of a

section 1291 fund and also for a brief summary of the tax

consequences for shareholders of a section 1291 fund.

Also, see Section 1291 Fund and Mark-to-Market

Election, earlier, for a brief discussion of when a

shareholder may be subject to section 1291 in the year

that it makes a mark-to-market election under any

provision of the Code, including section 1296.

Complete a separate Part V for each excess

distribution. That is, if you receive a distribution from a

section 1291 fund with respect to shares for which you

have different holding periods, complete lines 15a through

15e separately for each block of shares that has the same

holding period (“applicable stock”). If you dispose of stock

in a section 1291 fund for which you have different holding

periods, complete line 15f for each block of shares that

has the same holding period.

Line 15

In the entry space provided above line 15a, enter the

three-letter currency code of the currency used on lines

15a through 15e(1). Currency codes are available at sixgroup.com/en/products-services/financial-information/

data-standards.html#scrollTo=currency-codes.

The excess distribution must be determined in a single

currency. In general, the excess distribution must be

calculated in U.S. dollars. Each distribution is translated

into the U.S. dollar at the spot rate on the date on which

such distribution is made. However, if all distributions that

must be taken into account for purposes of calculating the

excess distribution are made in a single foreign currency,

the excess distribution must be calculated in the currency

in which the distributions are made. Each ratable portion

of a total excess distribution determined in such foreign

currency is then translated into U.S dollars at the spot rate

on the date of the distribution to which the ratable portion

is allocated. See section 1291(b)(3)(E) and Proposed

Regulations section 1.1291-2(d)(4).

Lines 15a and 15b

Enter your total distributions from the section 1291 fund

with respect to the applicable stock for the periods

indicated.

14

Note: A 10%-or-greater domestic corporation

shareholder might be able to claim a deemed paid foreign

tax credit under section 902 with respect to a distribution

from a section 1291 fund in the fund’s tax year beginning

before January 1, 2018. See Form 1118, Foreign Tax

Credits—Corporations, available at IRS.gov/Form1118, to

calculate the taxes deemed paid and the gross-up

amount.

Line 15a. If the holding period of the applicable stock

began in the current tax year, there is no excess

distribution and you should complete Part V as follows:

Enter on line 15a the total distributions you received from

the section 1291 fund with respect to that stock during the

current tax year. If you did not dispose of that stock during

the tax year, do not complete the rest of Part V. If you did

dispose of that stock during the tax year, skip lines 15b

through 15e and complete lines 15f and 16.

If the holding period of the applicable stock began in

the current tax year, the line 15a amount is taxed

according to the rules of section 301. To the extent that

section 301(c)(1) is applicable, include the amount as a

dividend on your income tax return. For corporations,

include this line 15a amount on Form 1120, Schedule C,

line 14. For individuals, include this line 15a amount on

Form 1040, line 3b (and, if applicable, on Schedule B

(Form 1040), line 5).

Line 15c

Divide the amount on line 15b by 3. If the number of tax

years in your holding period preceding the current tax year

is less than 3, divide the amount on line 15b by that

number.

Line 15e(1)

Nonexcess distribution. The nonexcess distribution is

the lesser of line 15a or line 15d. This amount is taxed

according to the rules of section 301. To the extent that

section 301(c)(1) is applicable, include the amount as a

dividend on your income tax return. For corporations,

include this amount on Form 1120, Schedule C, line 14.

For individuals, include this amount on Form 1040, line 3b

(and, if applicable, on Schedule B (Form 1040), line 5).

Excess distributions. If you received more than one

distribution during the tax year with respect to the

applicable stock, the excess distribution is apportioned

among all actual distributions. Each apportioned amount

is treated as a separate excess distribution.

Line 15f

Gain recognized on the disposition of stock of a section

1291 fund is treated as an excess distribution. Loss

realized on the disposition of stock of a section 1291 fund

is not taken into account under section 1291 and thus, for

example, does not reduce the amount of total gain subject

to section 1291. However, the loss may be recognized

under another provision of the Code and reported

accordingly. Stock of a section 1291 fund is considered

disposed of if it is sold, transferred, or pledged.

Instructions for Form 8621 (Rev. 12-2025)

Line 16

Lines 16a and 16b

Line 16d

Determine the taxation of the excess distribution on a

separate sheet and attach it to Form 8621. Divide the

amount on line 15e(2) or 15f, whichever applies, by the

number of days in your holding period. The holding period

of the stock is treated as ending on the date of the

distribution or disposition.

Special rules apply to the holding period if:

• The deemed dividend election (Election E) is made.

See the instructions earlier for Election E.

• The mark-to-market election (Election C) is made or

was made in a prior year (see section 1291(a)(3)(A)(ii)).

• The deemed dividend election with respect to a Section

1297(e) PFIC (Election G) or with respect to a Former

PFIC (Election H) is made. See the instructions for

Election G and Election H, earlier.

Determine the amount allocable to each tax year in

your holding period by adding the amounts allocated to

the days in each such tax year. Add the amounts allocated

to the pre-PFIC and current tax years. Enter the sum on

line 16b.

To figure the foreign tax credit, the shareholder of a

section 1291 fund figures the total creditable foreign taxes

attributable to the distribution. This amount includes the

withholding taxes paid by the shareholder on the

distribution and, in the case of the tax year of a section

1291 fund that begins before 2018, for 10%-or-greater

domestic corporate shareholders, any taxes deemed paid

under section 902. These taxes must be creditable under

general foreign tax credit principles, and the shareholder

must choose to claim the foreign tax credit for the current

tax year.

The excess distribution taxes (the creditable foreign

taxes attributable to an excess distribution) are

determined by apportioning the total creditable foreign

taxes between the part of the distribution that is an excess

distribution and the part that is not.

The excess distribution taxes are allocated in the same

manner as the excess distribution is allocated. See

Excess distributions, earlier. Those taxes allocated to

pre-PFIC tax years and the current tax year are taken into

account for the current tax year under the general rules of

the foreign tax credit.

This amount is treated as ordinary income (for

example, individuals and corporations should enter this

amount on the “other income” line of their tax return).

The excess distribution taxes allocated to a PFIC year

only reduce the increase in tax figured for that tax year

(but not below zero). No carryover of any unused excess

distribution taxes is allowed.

Line 16c

When you dispose of PFIC stock, the above foreign tax

credit rules apply only to the part of the gain that, without

regard to section 1291, would be treated under section

1248 as a dividend.

Determine the increase in tax for each tax year in your

holding period (other than the current tax year and

pre-PFIC years). An increase in tax is determined for each

PFIC year by multiplying the part of the excess distribution

allocated to each year (as determined on line 16a) by the

highest rate of tax under section 1 or section 11,

whichever applies, in effect for that tax year. Add the

increases in tax computed for all years. Enter the

aggregate increases in tax (before credits) on line 16c.

The following table sets forth the highest rate of tax in

effect under section 1 (applicable to individuals) for

calendar years 1987 through 2025.

Tax Rates

Tax year(s) (based on calendar Highest rate of tax in effect

year taxpayer)

under IRC section 1

2018–2025

37%

2013–2017

39.6%

2003–2012

35%

2002

38.6%

2001

39.1%

1993–2000

39.6%

1991–1992

31%

1988–1990

28%

1987

38.5%

Instructions for Form 8621 (Rev. 12-2025)

Line 16e

This amount is the total increase in tax and is included on

your tax return as additional taxes.

For individuals, include the amount as part of the total

for Form 1040, line 16. Check box 3 on line 16 and enter

“1291TAX” in the entry space for that box.

For corporations, enter this amount on Form 1120,

Schedule J, to the left of the entry space for line 1. Enter

“Sec. 1291” next to the amount and include it as part of

the total for line 1. Other entities should use the

comparable line on their income tax return.

Line 16f

Interest is charged on each net increase in tax for the

period beginning on the due date (without regard to

extensions) of your income tax return for the tax year to

which an increase in tax is attributable and ending with the

due date (without regard to extensions) of your income tax

return for the tax year of the excess distribution.

The amount of interest is determined by using the rates

and methods under section 6621. See section 1291(c)(3)

for more information regarding the computation of interest,

and also see Revenue Ruling 2024-18, 2024-37 I.R.B.

15

584 (or successor Revenue Ruling) for a list of historical

interest rates under section 6621.

For individuals, include the interest on Schedule 2

(Form 1040), line 17p.

For corporations, include the interest as part of the total

for Form 1120, Schedule J, line 9z. See the instructions

for Form 1120, Schedule J, line 9z.

Part VI. Status of Prior Year Section

1294 Elections and Termination of

Section 1294 Elections

Each person who has made a section 1294 election must

(1) complete lines 17 through 20 to annually report the

status of that election, and (2) complete lines 21 through

24 to report the termination of any section 1294 election

that occurred during the tax year. See Temporary

Regulations section 1.1294-1T(h).

Line 17. Enter the last day of each tax year for which you

made a section 1294 election that is outstanding. Enter as

MM/DD/YYYY. Do not include an election made in the

current tax year.

Line 18. Enter the undistributed earnings of the QEF in

the year for which the payment of tax was extended by the

section 1294 election entered on line 17. If the election

was partially terminated in a prior year, enter the

remaining undistributed earnings.

Line 19. Enter the tax for which payment was extended

by the section 1294 election entered on line 17. If the

election was partially terminated in the previous tax year,

enter the balance of the deferred tax from line 25 of the

prior year Form 8621.

Line 20. Enter the accrued interest (determined under

section 6621) on the deferred tax. This is the interest

accrued from the due date (not including extensions) of

the return for the year for which the section 1294 election

was made until the date the current year's return is filed.

Line 21. Enter the event(s) that occurred during the tax

year that terminated one or more of the section 1294

elections reported on line 17. A section 1294 election may

be terminated voluntarily. However, an election will

terminate automatically, in whole or in part, when any of

the following events occur.

• An actual or deemed distribution of earnings to which

the election is attributable (a loan, pledge, or guarantee by

the QEF to or for the benefit of the taxpayer may cause a

deemed distribution of the earnings);

• A disposition of stock in the QEF, including a pledge by

the taxpayer of stock as security for a loan; or

• A change of status of the QEF (that is, a foreign

corporation that is no longer a QEF or PFIC).

Line 22. Enter the earnings distributed or deemed

distributed as a result of the events described on line 21.

Earnings are treated as distributed out of the most

recently accumulated earnings and profits. Accordingly,

an event will first terminate the most recently made

election.

16

An election may be terminated in whole or in part

depending on the event causing the termination.

Examples are as follows.

• A distribution of earnings will terminate an election to

the extent the election is attributable to the earnings

distributed.

• A loan, pledge, or guarantee by the QEF made directly

or indirectly to the electing shareholder or related person

will terminate an election to the extent of the undistributed

earnings equal to the amount loaned, secured, or

guaranteed.

• A disposition of stock will terminate all elections with

respect to the undistributed earnings attributable to that

stock.

• A change in status of the QEF will terminate all

elections.

For more information, see Regulations section

1.1294-1T(e).

Line 23. Enter the deferred tax due from the termination

of the section 1294 election. The deferred tax entered on

line 19 is due if the election was completely terminated. If

the election was only partially terminated, a proportionate

amount of the deferred tax is due. That amount is

determined by multiplying the amount entered on line 19

by a fraction, of which the numerator is the amount

entered on line 22 and the denominator is the amount

entered on line 18. The deferred tax is due by the due

date of the shareholder's income tax return (without

regard to extensions) for the year of termination.

When the election is terminated, corporations include

the deferred tax as part of the total for Form 1120,

Schedule J, line 11. Also, enter the deferred tax to the left

of line 11 and label it as “Sec. 1294 deferred tax.”

For individuals, include the deferred tax as part of the

total for Schedule 2 (Form 1040), line 17z. Enter “1294DT”

and the amount of the deferred tax in the entry space for

that line.

Line 24. Enter the interest accrued on the deferred tax.

Interest accrues beginning on the due date (without

regard to extensions) of your tax return for the tax year in

which the section 1294 election is made and ending with

the due date (without regard to extensions) of your tax

return for the tax year of the termination. Interest is

computed using the rates and methods under section

6621.

For corporations, enter the amount of section 1294

interest on Form 1120, Schedule J, line 11, and label it as

“Sec. 1294 interest.”

For individuals, include the interest from line 24 on

Schedule 2 (Form 1040), line 17q.

Lines 25 and 26. Complete lines 25 and 26 only if a

section 1294 election is partially terminated. Enter on

line 25 the part of the deferred tax outstanding after the

partial termination of the section 1294 election. This

amount should equal line 19 minus line 23.

Note: As indicated in the line 19 instructions, for next

year, be sure to enter the line 25 amount of this year’s

Form 8621 on line 19 of next year’s Form 8621.

Instructions for Form 8621 (Rev. 12-2025)

Enter on line 26 the accrued interest remaining after the

partial termination of the section 1294 election. This

amount should equal line 20 minus line 24.

Instructions for Form 8621 (Rev. 12-2025)

17

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The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden

for individual taxpayers filing this form is approved under OMB control number 1545-0074 and the estimated burden for

business taxpayers is approved under OMB control number 1545-0123. The estimated burden for all other taxpayers

who file this form is shown below.

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If you have comments concerning the accuracy of these time estimates or suggestions for making this form simpler,

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18

Instructions for Form 8621 (Rev. 12-2025)