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Form 8621A: Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company
IRS Form 8621A is Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company. If the election year is a closed tax year, the taxpayer must enter into a closing agreement.
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IRS Form 8621A - Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company
IRS Form 8621A is Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company. If the election year is a closed tax year, the taxpayer must enter into a closing agreement.
Risk Radar
Scan points- 1Ensure you file the closing agreement in duplicate if the election year is a closed tax year.
- 2Failing to enter the correct amount as an excess distribution on Part IV, Line 9a.
- 3Not paying interest on the amount due for the period beginning on the due date (without extensions).
- 4Omitting required attachments referenced by lines in Part II or Part III.
- 5Forgetting to sign and date Form 8621A on page 2 of the form.
Plain English
This form allows a shareholder to make specific late elections that change how their stock from a foreign company (PFIC) is taxed. By filing this, the shareholder can end certain passive investment rules and calculate any resulting tax or interest due to the IRS.
Submission Date
- Filing date: 2025-02-06 22:10:34
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when a shareholder makes certain late elections to end treatment as a Passive Foreign Investment Company (PFIC).
- Do not use Form 8621A if the election is not being made by a shareholder, or if the PFIC does not require a late purging election.
- Check Form 8621-A instead when making a single late purging election for one PFIC.
Form selector
Use this form or another form?
Owning multiple related PFICs
A separate Form 8621-A must be filed for each Section 1297(e) or former PFIC in the chain.
✓ Check Part I elections to see which forms are needed.
Election year is a closed tax year
The closing agreement must be filed in duplicate, and both copies require original signatures.
✓ Ensure you attach the taxpayer copy correctly.
Form 8621-A (Page 3 Closing Agreement)
PFIC asset test uses adjusted basis
This applies if the corporation is not publicly traded OR makes an election to use adjusted basis.
✓ Confirm your chosen method aligns with the form's requirements.
Form 8621-A (Line/Part determination)
Deadline or filing window
The filing triggers an interest calculation period beginning on the due date (without extensions) of the income tax return for the election year. If the election year is a closed tax year, the taxpayer must also file the required closing agreement in duplicate.
Checklist
What you need before filling it out
PFIC Status Determination
Assets producing passive income or held for production of passive income · Instructions p.2
Closing Agreement Filing (Closed Year)
The closing agreement on page 3 · Instructions p.5 / Form p.1
Interest Calculation
Amount on line 18 from the due date up to filing date · Instructions p.5
Filing Requirement (General)
A separate Form 8621-A must be filed for each PFIC election being made. · Instructions p.1
Balance Sheet Completion
The balance sheet on page 4 · Instructions p.1
Before you submit
- 1Check the applicable box in Part I of Form 8621-A.
- 2Complete all applicable lines in Part II or III, including any requested attachments.
- 3Complete Part IV of Form 8621-A along with any required attachments for that part.
- 4Sign and date Form 8621-A on page 2.
- 5If the election year is closed, file the closing agreement (page 3) in duplicate with original signatures.
- 6Complete the balance sheet on page 4 if lines 4 or 8 require it.
- 7Keep a copy of the completed Form 8621-A for records.
How to file this form
- 1Complete Part I, II, III, and IV of Form 8621-A, ensuring all required attachments are included.
- 2Sign and date the form on page 2; if applicable (closed election year), complete the closing agreement on page 3 in duplicate.
- 3If necessary, complete the balance sheet on page 4.
- 4Make a check or money order payable to “United States Treasury,” ensuring you include your identifying number and “Form 8621-A” on the payment.
- 5Mail Form 8621-A (and attachments/closing agreement) to: Internal Revenue Service Deposit Team, M/S 6059 Attn: Specials Desk Ogden, UT 84201.
Known limitations
- 1A separate Form 8621-A must be filed for each Passive Foreign Investment Company (PFIC) for which a late purging election is being made.
- 2If a shareholder owns one PFIC and that PFIC owns other PFICs, the shareholder must file a separate Form 8621-A for each Section 1297(e) or former PFIC in the chain for which a late purging election is made.
- 3The form does not apply to all situations; specifically, if the determination of whether a foreign corporation is a PFIC involves it owning at least 25% (by value) of another corporation, that foreign corporation is treated as holding a proportionate share of assets and income.
Field map
Compact field-by-field guide
General Info
2 items
Full legal name and taxpayer identification number (SSN or EIN).
Current mailing address.
Details
2 items
Complete all applicable sections of this form according to the official IRS instructions.
Enter the relevant dollar amount if this form involves tax calculation.
Certification
1 items
Read and acknowledge any certifications required by this form.
Signatures
1 items
Sign and date. Unsigned forms cannot be processed.
Almost done reviewing the fields?
Fillable formOpen in Editor->The current edition is Revision December 2024 (Rev. 12-2024). For the latest information, reference IRS.gov/Form8621A, which indicates an OMB number revision to 1545-1002.
What changed or needs a fresh check
- Edition date — confirm the revision reads December 2024.
- OMB number — confirm the number shown on page 1 is 1545-1002.
- Mailing address — verify the IRS Deposit Team address is Ogden, UT 84201.
- Signature — ensure signatures are provided in the spaces at the bottom of page 2.
- Payment detail — confirm your check/money order is payable to “United States Treasury.”
Quick Facts
Downloads
After you file
- 1Keep a copy of Form 8621-A for personal records.
- 2If the election year is a closed tax year, ensure both copies of the closing agreement (on page 3) contain original signatures.
- 3When paying, make the check or money order payable to “United States Treasury” and include your identifying number and “Form 8621-A” on the payment.
- 4If Form 8621-A does not include full payment of the amount shown on line 21, the form will not be processed.
Sources
- SRCInstructions p.1 — The official title is Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company.
- SRCInstructions p.1 — A separate Form 8621-A must be filed for each PFIC for which a late purging election is being made.
- SRCInstructions p.1 — The shareholder files Forms 8621-A together when owning one PFIC that owns others in the chain.
- SRCInstructions p.1 — Form 8621-A must be filed with the Internal Revenue Service Deposit Team at M/S 6059 Attn: Specials Desk, Ogden, UT 84201.
- SRCInstructions p.1 — If the election year is a closed tax year, file the closing agreement on page 3 in duplicate; both copies need original signatures.
- SRCInstructions p.2 — A PFIC is considered a Qualified Electing Fund (QEF) if the U.S. person elects this status under section 1295.
- SRCForm p.1 — The current edition revision date is December 2024, and the OMB number is 1545-1002.
Common confusion points
What is a Shareholder?
A shareholder is defined as a U.S. person that is a direct or indirect shareholder of the foreign corporation.
What is a CFC?
Controlled Foreign Corporation (CFC) is defined in section 957(a) for definition.
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- A separate Form 8621-A must be filed for each PFIC in a chain of ownership.
Questions about IRS Form 8621A
What is IRS Form 8621A used for?
This form allows a shareholder to make specific late elections that change how their stock from a foreign company (PFIC) is taxed. By filing this, the shareholder can end certain passive investment rules and calculate any resulting tax or interest due to the IRS.
Who must file IRS Form 8621A?
The election can be made by a U.S. person that is a shareholder of a former PFIC for Election A; a shareholder of a foreign corporation that is a Section 1297(e) PFIC for Elections C and D; or a U.S. person for Election D.
What information does IRS Form 8621A require?
The form collects information in Part I (election details), Part II or III (specific transaction data, such as the tax year or acquisition description), and Part IV (computation of Tax and Interest Due). The balance sheet is completed on page 4 if required by lines 4 or 8.
When is IRS Form 8621A due?
The election must be filed with the IRS; interest calculation begins from the due date (without extensions) of the income tax return for that election year. If the election year is a closed tax year, the closing agreement must also be filed.
Where do I file IRS Form 8621A?
The form requires signing and dating in the spaces provided at the bottom of page 2. The instructions state to file it with the IRS, but do not specify a service center address for general filing.
How do I complete IRS Form 8621A?
First, check the applicable box in Part I. Then, complete the required lines in either Part II or Part III based on the election chosen, along with any attachments requested. Finally, complete Part IV to compute the tax and interest due before signing and dating the form on page 2.
What happens if IRS Form 8621A is filed incorrectly?
Failure to pay interest on the amount due determined for the period beginning on the due date (without extensions) can result from incorrectly completing Form 8621A.
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