From: jeffrey E. <jeevacation@gmail.com>
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

P. <u><tel</u> > F. <u><tel</u>
<mailto:

From: Richard =ahn [mailto <mailto >j Sent: Thursday, June 12, 2014 4:06 PM To: Dlugash, Alan Subject: Re: JEE 8621

please call me as we need to know tax rules, t=en review with jee before monday withdrawal deadline

thanks

Richard Kahn
HBRK Associates Inc.
575 Lexington Avenue 4th Floor
New York, NY 10022
tel:  <tel:
fax:  <tel:
cell =  <tel:

On Jun 11, 2014, at 7:11PM, Dlugash, Alan <=
<mailto > > wrote:

The (obvious) answer was that the info was per the Form 8621(PFIC infor=ation return) that was attached to Jeff's 1040, as it has been eve=y year.

Alan<=p>

ALAN DLUGASH CPA</=>

=C2

Marks Paneth LLP is located at 685 Third Avenue, New York, NY, 10017.
Contact information includes a phone number (P) and email (E). A fax number (F) is also listed. The contact information is obscured in the image.

<image001.gif>

-----Original Message-----
From: Sayar, Edward
Sent: Wednesday, June 11, 2014 5:38 PM
To: Dlugash, Alan
Subject: FW: JEE 8621

It was included as an attachment to his 2012 1040.

EDWARD A. SAYAR, EA, Manager

Tax

Marks Paneth LLP

Marks Paneth LLP
685 Third Avenue, New York, NY, 10017

P. [redacted] <tel:...>   F. [redacted] <tel:...>
E. [redacted] = <mailto:...>

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