[Federal Register Volume 87, Number 100 (Tuesday, May 24, 2022)]
[Notices]
[Page 31632]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-11125]



[[Page 31632]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Return by a Shareholder 
Making Certain Late Elections To End Treatment as a Passive Foreign 
Investment Company

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

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SUMMARY: The Internal Revenue Service, as part of its continuing effort 
to reduce paperwork and respondent burden, invites the general public 
and other Federal agencies to take this opportunity to comment on 
continuing information collections, as required by the Paperwork 
Reduction Act of 1995. The IRS is soliciting comments concerning the 
return by a shareholder making certain late elections to end treatment 
as a passive foreign investment company.

DATES: Written comments should be received on or before July 25, 2022 
to be assured of consideration.

ADDRESSES: Direct all written comments to Andres Garcia, Internal 
Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 
20224, or by email to [email protected]. Include OMB control number 
1545-1950 or Return by a Shareholder Making Certain Late Elections To 
End Treatment as a Passive Foreign Investment Company.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the form should be directed to Kerry Dennis at (202) 317-
5751, or at Internal Revenue Service, Room 6526, 1111 Constitution 
Avenue NW, Washington, DC 20224, or through the internet, at 
[email protected].

SUPPLEMENTARY INFORMATION: 
    Title: Return by a Shareholder Making Certain Late Elections To End 
Treatment as a Passive Foreign Investment Company.
    OMB Number: 1545-1950.
    Form Number: 8621-A.
    Abstract: Form 8621-A is necessary for certain taxpayers/
shareholders who are investors in passive foreign investment companies 
(PFIC's) to request late deemed sale or late deemed dividend elections 
(late purging elections) under Reg. 1.1298-3(e). The form provides a 
taxpayer/shareholder the opportunity to fulfill the requirements of the 
regulation in making the election by asserting the following: (i) The 
election is being made before an IRS agent has raised on audit the PFIC 
status of the foreign corporation for any taxable year of the taxpayer/
shareholder; (ii) the taxpayer/shareholder is agreeing (by submitting 
Form 8621-A) to eliminate any prejudice to the interests of the U.S. 
government on account of the taxpayer/shareholder's inability to make 
timely purging elections; and (iii) the taxpayer/shareholder shows as a 
balance due on Form 8621-A an amount reflecting tax plus interest as 
determined under Reg. 1.1298(e)(3).
    Current Actions: There is no change in the paperwork burden 
previously approved by OMB.
    Type of Review: Extension of a currently approved collection.
    Affected Public: Individuals and households, businesses and other 
for-profit organizations.
    Estimated Number of Respondents: 1.
    Estimated Time per Respondent: 78 hours, 30 minutes.
    Estimated Total Annual Burden Hours: 79 hours.
    The following paragraph applies to all the collections of 
information covered by this notice.
    An agency may not conduct or sponsor, and a person is not required 
to respond to, a collection of information unless the collection of 
information displays a valid OMB control number. Books or records 
relating to a collection of information must be retained if their 
contents may become material in the administration of any internal 
revenue law. Generally, tax returns and tax return information are 
confidential, as required by 26 U.S.C. 6103.
    Request for Comments: Comments submitted in response to this notice 
will be summarized and/or included in the request for OMB approval. All 
comments will become a matter of public record. Comments are invited 
on: (a) Whether the collection of information is necessary for the 
proper performance of the functions of the agency, including whether 
the information shall have practical utility; (b) the accuracy of the 
agency's estimate of the burden of the collection of information; (c) 
ways to enhance the quality, utility, and clarity of the information to 
be collected; (d) ways to minimize the burden of the collection of 
information on respondents, including through the use of automated 
collection techniques or other forms of information technology; and (e) 
estimates of capital or start-up costs and costs of operation, 
maintenance, and purchase of services to provide information.

    Approved: May 19, 2022.
Kerry L. Dennis,
Tax Analyst.
[FR Doc. 2022-11125 Filed 5-23-22; 8:45 am]
BILLING CODE 4830-01-P