Guidance on Passive Foreign Investment Companies and Controlled Foreign Corporations Held by Domestic Partnerships and S Corporations and Related Person Insurance Income
Guidance on Passive Foreign
Investment Companies and Controlled Foreign Corporations Held by
Domestic Partnerships and S Corporations and Related Person
Insurance Income
New
collection (Request for a new OMB Control Number)
No
Regular
01/31/2022
Requested
Previously Approved
36 Months From Approved
1,373,425
0
686,713
0
0
0
The collection of information in Prop
Regs sections 1.1295-1(d)(2)(i)(A), 1.1295-1(d)(2)(ii)(A), and
1.1296-1(h)(1)(i)(A) is for partners or S corporation shareholders
that own an interest in a PFIC through a partnership or S
corporation to notify the partnership or S corporation that it has
made a QEF or MTM election (under section 1295 or section 1296,
respectively) with respect to the PFIC no later than 30 days after
filing the return on which the election is made; notification of
the election may be provided in any reasonable manner. Under
§1.958-1(d), S corporations are not considered as owning CFC stock
under section 958(a), and thus are not subject to inclusions under
section 951 or section 951A. Proposed §1.958-1(e) permits an S
corporation to elect to be treated as owning stock in a CFC under
section 958(a) if it meets certain conditions, including having
accumulated earnings and profits as of a certain date. This
recordkeeping requires S corporations that make this election to
maintain sufficient records substantiating their accumulated
earnings and profits amount.
US Code:
26
USC 951A Name of Law: Global intangible low-taxed income
included in gross income of United States shareholders
US Code: 26
USC 951 Name of Law: Amounts included in gross income of United
States shareholders
There is an increase in burden
as this is a new NPRM and information collection.
$0
No
No
No
No
No
No
No
Edward Tracy 202
317-4993
No
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.