[Federal Register Volume 89, Number 183 (Friday, September 20, 2024)]
[Notices]
[Pages 77239-77240]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-21515]


-----------------------------------------------------------------------

DEPARTMENT OF THE TREASURY

Internal Revenue Service


Proposed Collection; Comment Request for Information Collection 
Tool Relating to the Return by a Shareholder of a Passive Foreign 
Investment Company or Qualified Electing Fund

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice and request for comments.

-----------------------------------------------------------------------

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 return 
by a shareholder of a passive foreign investment company or qualified 
electing fund and 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 November 19, 
2024 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 
1545-1002 or Form 8821 and Form 8821-A in the subject line of the 
message.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or 
copies of the form should be directed to Molly Stasko, at (202) 317-
6206 or Internal Revenue Service, Room 6526, 1111 Constitution Avenue 
NW, Washington, DC 20224, or through the internet, at 
[email protected].

SUPPLEMENTARY INFORMATION: 
    Titles: Return by a Shareholder of a Passive Foreign Investment 
Company or Qualified Electing Fund and Return by a shareholder making 
certain late elections to end treatment as a passive foreign investment 
company.
    OMB Number: 1545-1002.
    Form Numbers: 8621and 8621-A.
    Abstract: Form 8621 is filed by a U.S. shareholder who owns stock 
in a foreign investment company. The form is used to report income, 
make an election to extend the time for payment of tax, and to pay an 
additional tax and interest amount. The IRS uses Form 8621 to determine 
if these shareholders have correctly reported amounts of income, made 
the election correctly, and have correctly computed the additional tax 
and interest amount. 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/

[[Page 77240]]

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: IRS is making an administrative change to merge 
the previously approved OMB 1545-1950-Form 8621-A into the OMB approval 
of 1545-1002. There are no changes to either form or its use.
    Type of Review: Revision of a currently approved collection.
    Affected Public: Businesses or other for-profit organizations and 
individuals.
    Form 8621:
    Estimated Number of Respondents: 1,333.
    Estimated Time per Response: 48 hours, 44 min.
    Estimated Total Annual Burden Hours: 64,971.
    Form 8621-A:
    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.

    Dated: September 17, 2024.
Sara L. Covington,
IRS Tax Analyst.
[FR Doc. 2024-21515 Filed 9-19-24; 8:45 am]
BILLING CODE 4830-01-P