Search found 2 matches

by mabeau
Wed Apr 11, 2018 10:11 am
Forum: Canada / United States Tax & Accounting
Topic: PFIC Form 8621 Part 1 Summary QEF election
Replies: 3
Views: 3459

That the inclusion is the ordinary income plus net capital gains makes sense from 1293(a). However, if there are distributions that year, 1293(c) of the code ("such distribution shall immediately reduce earnings and profits") seems to imply that this distribution should be removed from the...
by mabeau
Thu Apr 05, 2018 11:59 am
Forum: Canada / United States Tax & Accounting
Topic: PFIC Form 8621 Part 1 Summary QEF election
Replies: 3
Views: 3459

PFIC Form 8621 Part 1 Summary QEF election

I purchased a PFIC in 2017 which provides a PFIC Annual Information Statement and for which I intend to make the QEF election this first year of ownership. I believe I have a decent understanding of what is required for the QEF election on Form 8621, except for Question 5 of the Part I Summary secti...