Reporting guidance for PFIC shareholders and specified foreign financial assets
On June 21, 2011, the IRS issued Notice 2011-55, which provides that the new information reporting requirements under sections 1298(f) (relating to passive foreign investment company (PFICs)) and 6038D (relating to specified foreign financial assets) are suspended until the IRS releases revised Form 8621 and Form 8938, respectively. Nonetheless, Forms 8621 and 8938 will be required to be attached to the next subsequent return to reflect any reportable information relating to a period under which this suspension is in effect. Notice 2011-55 only provides a delay, and not an exemption, from these new reporting requirements.
Larry LeBlanc, Managing Director, Vienna, VA