TD 9360 (Final) - Guidance on Passive Foreign Company (PFIC) Purging Elections
Extension without change of a currently approved collection
No
Regular
02/28/2022
Requested
Previously Approved
36 Months From Approved
02/28/2022
250
250
250
250
0
0
Section 1.1297-3T(c) allows a shareholder of a 1297(e) PFIC to make a deemed dividend election pursuant to which the shareholder includes in income as a dividend its pro rata share of the post-1986 earning and profit of the PFIC attributable to all of the stock it held, directly or indirectly on the CFC qualification date, as defined in 1.1297-3T(d). The IRS needs the information to substantiate the taxpayer's computation of the taxpayer's share of the PFIC's post-1986 earning and profits.
US Code:
26 USC 1297
Name of Law: Passive foreign investment company.
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.
SUP STAT (TD 9360).docx
TD 9360 (Final) - Guidance on Passive Foreign Company (PFIC) Purging Elections