dellpaul wrote: The Form 8992 should be filed even if the high-tax exception election is made (be sure to attach the election to the tax return).
Who Must File
A U.S. shareholder (including a partner of a domestic partnership) that owns, within the meaning of section 958(a), stock in one or more CFCs. See Regulations sections 1.951A-1(e) and 1.6038-5(a).
If any person required to file Form 8992 (or successor form) under section 6038 and this section fails to furnish the information prescribed on Form 8992 within the time prescribed by paragraph (b) of this section, the penalties imposed by section 6038(b) and (c) apply.
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