Part I. Summary — Instruction 8621 — Instructions for Form

Who Must Complete Part I In general, all shareholders required to file Form 8621 under section 1298(f) and the regulations thereunder must complete Part I. However, a shareholder of a PFIC that is marked to market under a Code provision other than section 1296 (such as section 475) is not required to complete Part I unless it is subject to section 1291 with respect to the PFIC pursuant to Regulations section 1.1291-1(c)(4)(ii). See T.D. 9806. Shareholders filing a joint return may file a single Form 8621 with respect to a single PFIC in which each joint filer owns an interest.

Shareholders that are the first U.S. person in the chain of ownership. Regulations section 1.1298-1 generally requires a U.S. person that is at the lowest tier in a chain of ownership (that is, the first U.S. person in the chain of ownership) and that is a shareholder (including an indirect shareholder) of a PFIC to complete Part I for each PFIC owned by that shareholder during the shareholder’s tax year.

In the case of an entity classification election that is made on behalf of a PFIC, QEF, or QIC on Form 8832, Regulations section 301.6109-1(b)(2)(v) requires the PFIC, QEF, or QIC to have an EIN for this election. For the first year that Form 8621 is filed after an entity classification election is made on behalf of the PFIC, QEF, or QIC on Form 8832, the new EIN must be entered in the applicable entry space above Part I of Form 8621 and the old reference ID number must be entered in the applicable entry space just below. In subsequent years, the Form 8621 filer may continue to enter both the EIN and the reference ID number, but must enter at least the EIN.

You must correlate the reference ID numbers as follows: New reference ID number [space] Old reference ID number. If there is more than one old reference ID number, you must enter a space between each such number. As indicated above, the length of a given reference ID number is limited to 50 characters and each number must be alphanumeric and no special characters are permitted.

Requirements. The reference ID number must be alphanumeric (defined below), and no special characters or spaces are permitted. The length of a given reference ID number is limited to 50 characters.

For these purposes, the term “alphanumeric” means the entry can be alphabetical, numeric, or any combination of the two.

The same reference ID number must be used consistently from tax year to tax year with respect to a given PFIC, QEF, or QIC. If for any reason a reference ID number falls out of use (for example, the PFIC, QEF, or QIC no longer exists due to disposition or liquidation), the reference ID number used for that PFIC, QEF, or QIC cannot be used again for another PFIC, QEF, or QIC for purposes of Form 8621 reporting.

Specific filing requirements apply with respect to Domestic grantor trusts , as described later in these Instructions.

Exceptions to these filing requirements are described later under Exceptions to Filing Part I .

There are some situations that warrant correlation of a new reference ID number with a previous reference ID number when assigning a new reference ID number to a PFIC, QEF, or QIC. For example:

In the case of a merger or acquisition, a Form 8621 filer must use a reference ID number that correlates the

Shareholders that are not the first U.S. person in the chain of ownership. In general, an indirect shareholder that is not the first U.S. person in the chain of ownership is not required to complete Part I unless the indirect shareholder:

Is treated as receiving an excess distribution from the PFIC;

Instructions for Form 8621 (Rev. 12-2025) 5

Is treated as recognizing gain that is treated as an excess distribution as a result of a disposition of the PFIC;

to complete Part I with respect to a specific section 1291 fund if the shareholder meets the $25,000 exception on the last day of the shareholder’s tax year and the shareholder does not receive an excess distribution from, or recognize gain on the sale or disposition of the stock of, the section 1291 fund. For purposes of determining whether a shareholder satisfies the $25,000 threshold, the shareholder takes into account all PFIC stock (QEFs, section 1291 funds, and PFIC stock subject to a section 1296 mark-to-market election) owned directly or indirectly other than PFIC stock owned through another U.S. person or PFIC stock owned through another PFIC. Shareholders filing a joint return have a combined threshold of $50,000 instead of $25,000 for purposes of this exception.

For more information, see Regulations section 1.1298-1(c)(2).

Is required to include an amount in income under section 1293(a) with respect to the PFIC, unless another shareholder through which the indirect shareholder owns the PFIC files under section 1298(f) with respect to the PFIC and no other exception applies;
Is required to include an amount in income under section 1296(a) with respect to the PFIC, unless another shareholder through which the indirect shareholder owns the PFIC files under section 1298(f) with respect to the PFIC; or
Is required to report the status of a section 1294 election with respect to the PFIC.

See Regulations section 1.1298-1(b)(2) for further information.

Domestic grantor trusts. In general, a U.S. grantor of a domestic grantor trust that owns an interest in a PFIC (directly or indirectly) through one or more foreign entities must complete Part I with respect to that PFIC interest. See Regulations sections 1.1291-1(b)(8)(iii)(D) and 1.1298-1(b)(1)(iii). In those circumstances, a domestic grantor trust is not required to complete Part I with respect to the stock of the PFIC that is owned by the grantor. For certain exceptions, see Regulations section 1.1298-1(b) (3)(i).

Exceptions To Filing Part I A shareholder is exempt from completing Part I if it meets one of the exceptions described below.

Special rules for estates and trusts. Certain U.S. grantors and beneficiaries of estates and trusts may qualify for an exception to filing Part I.

A U.S. grantor of a domestic grantor trust is not required to complete Part I if the trust is a domestic liquidating trust or a widely held fixed investment trust, as described in Regulations section 1.1298-1(b)(3)(i). In these circumstances, the domestic grantor trust is required to complete Part I.
In certain situations, a shareholder who is a member or beneficiary of (or participant in) an arrangement treated as a foreign pension fund under a U.S. income tax treaty that owns an interest in a PFIC is not required to complete Part I with respect to the PFIC. See Regulations section 1.1298-1(c)(4).
A U.S. beneficiary of a foreign nongrantor trust or foreign estate is not required to complete Part I with respect to the stock of the PFIC that is owned by the trust or estate unless it has made a QEF or section 1296 mark-to-market election, received an excess distribution, or recognized gain treated as an excess distribution with respect to the stock of the PFIC. See Regulations section 1.1298-1(b)(3)(ii).

Exempt organizations. In general, if a shareholder of a PFIC is a tax-exempt organization, the shareholder is required to complete Part I only if income derived with respect to the PFIC stock would be taxable to the shareholder under subchapter F. See Regulations section 1.1298-1(c)(1).

Exception if aggregate value of shareholder’s PFIC stock is $25,000 or less. A shareholder is not required

Exception if the value of shareholder’s indirect PFIC stock is $5,000 or less. A shareholder is not required to complete Part I with respect to indirect ownership of a specific section 1291 fund if the shareholder meets the $5,000 exception with respect to the section 1291 fund on the last day of the shareholder’s tax year and the shareholder does not receive an excess distribution from, or recognize gain on the sale or disposition of the stock of, the section 1291 fund. For purposes of determining whether a shareholder satisfies the $5,000 threshold, the shareholder takes into account only the value of the shareholder’s proportionate share of the section 1291 fund.

For more information, see Regulations section 1.1298-1(c)(2).

Line Instructions

Line 1. Describe each class of shares held by the shareholder.

Line 2. Provide the date during the tax year that the shares were acquired, if applicable.

Line 3. List the number of shares held at the end of the tax year.

Line 4. Indicate the value of the shares held at the end of the tax year. Shareholders may rely upon periodic account statements provided at least annually to determine the value of a PFIC unless the shareholder has actual knowledge or reason to know based on readily accessible information that the statements do not reflect a reasonable estimate of the PFIC’s value.

Line 5. Indicate the type of PFIC and the amount of any excess distribution or gain treated as an excess distribution under section 1291, inclusion under section 1293, and inclusion or deduction under section 1296.

Note: In cases in which a shareholder’s ownership interest in a PFIC is not denominated in shares, the shareholder must provide the information for lines 1 through 4 based on its form of ownership in the PFIC.

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