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Practitioner’s Guide to the Sec. 965 Repatriation Tax
Practitioner’s Guide to the Sec. 965 Repatriation Tax

Join special guest instructor Mary Beth Lougen, EA, USTCP for the Compass Tax Educators webinar “Practitioner’s Guide to the Sec. 965 Repatriation Tax” on April 3, 2018. Other members of the Compass Tax Educators team will also be available on this webinar to moderate the event and answer questions.

The Tax Cuts & Jobs Act completely redefined the U.S. tax regime for foreign corporations owned by U.S. persons. To facilitate this change, Congress imposed a one-time tax on certain offshore earnings: the learning curve is steep, the IRS issued guidance only last week, and the timeline for our clients is very short. This course outlines the who, what, when, where, and, most importantly, how of computing and paying this tax.

The learning objectives for this webinar include:

  • Recognize the new terminology and expanded definitions in §965.
  • Identify taxpayers who are subject to the §965 repatriation tax.
  • Apply IRS guidance to compute the §965 repatriation tax.
  • Prepare the election to pay the §965 tax over 8 years.

More Information & Registration

Form 8621 Calculator – Walk-through training
Form 8621 Calculator – Walk-through training

Recorded on February 14, 2018. In this hour long training video for the Form 8621 Calculator you will be presented with a detailed explanation of the work-flow, setting up clients and investment portfolios, a how to guide to complete form 8621s using our software. You will also learn how to make elections under Mark to Market, QEF, and OVDP. As well as tips and best practices to save you time and money when working with PFICs.

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Form 8621 Calculator Update v18.01.01


  • 2017 CCH Tax Preparation Program data entry update


  • Removed disallowed Foreign Tax Credits credits the form 8621
  • Deemed Sale Fair Market Value currency fix
Form 8621 Calculator Update v18.01.00


  • Currency update 2017 December
  • 2017 interest and tax rates
  • 2017 forms and calculations
Upcoming conference exhibits
Upcoming Training Sessions

Upcoming trainings and presentations

PFIC related:

  • Potential Issues and Benefits
  • Identification, reporting, elections
  • PFIC/8621 Case Study

International Taxation:

  • Foreign Earned Income Exclusion & Other Things International;
  • The Canadian In America
IRS fines Toronto man $165,000 for not filing forms; CRA helped collect

By Patrick Cain
National Online Journalist, News Global News

A U.S. federal court has upheld a $165,000 penalty against a Toronto man for not filing forms reporting his Canadian business on his U.S. tax returns.
Donald Dewees, a 76-year-old U.S. citizen, has been living in Canada since 1971. He had been paying taxes in Canada, but not filing U.S. tax returns, which U.S. law required him to do.
His lawyer, Mark Feigenbaum, calls it “a rule that a lot of people don’t know about.”

Read the full article at Global News.

Form 8621 Update: Consolidated Forms Guide (v17.03.02)


New Features

  • Consolidated Forms Guide
  • Export consolidated tax software grids for Schedule D and Schedule B
  • Form 1040 Statements for consolidated report: Line 21, Additional Tax and Interest, Form 1116 Line 12
  • Election in settings to use or opt out of the new consolidated reporting.
  • List Reference ID in Forms and Fund list
  • Order forms list by reference ID


  • PDF report fix when the transitional rule is applied
  • Remove the day of purchase from the holding period when counting days
Form 8621 Update: QEF Calculation Module (v17.03.01)


Expat Tax Tools is pleased to announce the release of our newest calculation module for completing the Form 8621 for Qualified Electing Funds (QEF).

The new QEF module includes both the pedigreed and un-pedigreed calculations, deemed sale elections, and prior year adjustments (when needed).

Also included in this release the following exciting new features:

  • Hiding or Showing PFIC investments that are sold in the form view screen;
  • Ability to enter per-share transaction amounts;
  • Ability to add notes to transactions and making an election whether the note appears on the PDF statement or not.

Additional changes:

  • Removed the alternate data entry option;
  • Removed the pop-up notification when the current transaction is over or under the set threshold amount.
The Trouble with QEF Reporting


Wolters Kluwer

Mary Beth Lougen examines the issues surrounding the sale of a fiscal year qualified electing fund (QEF) by passive foreign investment companies (PFICs).

Practitioners that work with clients who have international connections often have to run the gauntlet of Code Secs. 1291–1298, the portion of the statute that covers passive foreign investment companies or PFICs. As someone who frequents the PFIC regulations, I am always in awe of this section of the Internal Revenue Code (“the Code”). The men and women who took the directive provided by Congress in the Tax Reform Act of 1986 and put to paper how we are to treat passive foreign investment companies on a U.S. tax return were geniuses. They have woven an intricate and complex web of “if this, then that” rules that speak to many other sections of the Code—if the PFIC is also a CFC, then … , if the shareholder becomes a U.S. person after already owning an investment that became a PFIC the minute they crossed into U.S. personhood, then … , if the investment was owned prior to 1987 when the regulations came into play, then … . But there is one place where the interaction between the PFIC rules and the rest of the regulations is not in sync, this is the case when there is a sale of a fiscal year qualified electing fund (QEF) during the period between the end of the fiscal reporting year and the taxpayer’s calendar year end.

It is widely thought that QEF election is the best solution to a bad problem— but I am going to have to disagree, or at least disagree when the PFIC reports on a fiscal year.