Guidance on Passive Foreign Investment Companies and Controlled Foreign Corporations Held by Domestic Partnerships and S Corporations and Related Person Insurance Income

ICR 202112-1545-008

OMB: 1545-2303

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2022-01-31
ICR Details
202112-1545-008
Received in OIRA
TREAS/IRS
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
  
None

1545-BP94 Proposed rulemaking 87 FR 3890 01/25/2022

No

  Total Request Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 1,373,425 0 0 1,373,425 0 0
Annual Time Burden (Hours) 686,713 0 0 686,713 0 0
Annual Cost Burden (Dollars) 0 0 0 0 0 0
Yes
Changing Regulations
No
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.
01/31/2022


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