The IRS adopted final regulations (TD 9806) on determining the ownership of a passive foreign investment company (PFIC), reporting requirements for shareholders of PFICs to file Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund and on an exception to the requirement for certain shareholders to file Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations.

These regulations adopt proposed regulations that were issued in December of 2013 with certain changes. As well, the related temporary regulations are removed. The changes are effective December 28, 2016.