From: jeffrey E. <[email protected]> Sent: Friday, June 13, 2014 3:21 PM To: Dlugash, Alan Subject: Re: JEE Form 8621 alan call me On Fri, Jun 13, 2014 at 11:10 AM, Dl=gash, Alan < <mailto wrote: Rich, => > =AO I am writing regarding the tax issue of what t=iggers the termination of the extension of time to pay the PFIC tax. We ha=e deferred the tax otherwise due from 1999 through 2006, but we have been paying the tax on all earnings reported since then. Th= termination of the extension is basically triggered by either or both of = occurances: 1) the distribution fr=m the PFIC to the shareholder of the income whose tax is being deferred. 1= our case, this would be a distribution from the PFIC to the investment pa=tnership in which Haze is the investor. Typically there would not be distributions as long as the PFIC investment =ontinues being held by the investment partnership. If there are any distri=utions, they would be deemed to come out of the most RECENT earnings - per=ect in our case, since these would be the earnings on which we have already paid tax. 2) the disposition of =he shares to which the deferral is attributable. It appears that each PFIC=share would carry with it its share of the deferral from each year. Our on=y wrinkle is that it is not the investment partnership selling its PFIC shares, but rather Haze is selling a share of=its investment in the investment partnership. Let'= discuss. Alan ALAN DLUGASH CPA Marks Paneth LLP<=r> 685 Third Avenue, New York, NY, 10017 EFTA_R1_01764379 EFTA02585084