Form 8621-2025

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There is no penalty for not filing this form when you are supposed to. However, the statute of limitations for assessing penalties is suspended until you do file the form, if required. That means your entire return remains subject to audit until three years after you file the required Form 8621.
Meanwhile, Form 8621 falls under the IRS regulation that requires expat taxpayers to report investments in mutual funds and other pooled investments. It is a more specific report of a source of income compared to the general scope of Form 8938.
A U.S. person that is a direct or indirect shareholder of a passive foreign investment company (PFIC) files Form 8621 if they: Receive certain direct or indirect distributions from a PFIC. Recognize a gain on a direct or indirect disposition of PFIC stock.
Generally, not everyone needs to file a tax return each year. In fact, you wont need to file a tax return unless your total income exceeds certain thresholds, or you meet specific filing requirements. Typically, if your income is less than the Standard Deduction, you dont need to file a tax return.
Annual Filing: Generally, Form 8621 must be filed annually with the taxpayers federal income tax return. Reporting Income: Taxpayers must report their share of earnings and any gains distributed or recognized on PFIC investments.
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If you request certification under this procedure, you must submit a Form 8802 for each year, but in years 2 and 3 you only need to attach a copy of the year 1 Form 8802 (including the penalties of perjury statement), provided there are no material changes to the information entered on the Form 8802 in year 1.
The thresholds for reporting are: Single or married filing separately: More than $25,000 in PFICs. Married filing jointly: More than $50,000 in PFICs.

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