Very unfamiliar with PFICs and Form 8621 reporting. Could use some general guidance from anyone here who has worked with them.
Clients mother passed away in 2021, his nongrantor trust is the beneficiary of her estate. Mother owned PFIC, which transferred ownership to the trust.
We JUST received the PFIC statement, so I have the income information.
Where I am unsure, is if the nongrantor trust itself has to file the PFIC statement and pickup the income, or if the individual beneficiary has to. (Additionally, the beneficiary took no distributions from the trust in 2021)
From what I have been able to research, the rules on this are unclear. The below quote is the most recent info I have found, but I do not know if any guidance was released after this:
"However, beneficiaries of domestic estates and nongrantor trusts may be indirect owners.82 Thus, it is uncertain whether a domestic trust that makes a QEF election can report income from the PFIC as a result of the QEF election and pay tax on such income to the extent distributions are not made to beneficiaries (applying the usual rules of subchapter J), or whether the beneficiaries who are deemed to be the indirect owners must report the income whether or not received."
Thanks all,. let me know if you need additional facts.