Printable Form 2026

IRS Form 8927 – Determination Under Section 860(e)(4) by a Qualified Investment Entity

IRS Form 8927  – Qualified Investment Entities (QIEs)—including Real Estate Investment Trusts (REITs) and Regulated Investment Companies (RICs) —sometimes discover adjustments that increase taxable income or reduce their dividends-paid deduction for a prior tax year. Internal Revenue Code (IRC) Section 860 provides a powerful remedy: the deficiency dividend deduction. To trigger this safely via self-determination, entities file IRS Form 8927.

This comprehensive guide explains everything about IRS Form 8927 using only official IRS sources (as of February 2026). Learn its purpose, who files it, how to complete it, filing rules, and its role in claiming deficiency dividends.

What Is IRS Form 8927?

Form 8927 (Rev. December 2016), titled Determination Under Section 860(e)(4) by a Qualified Investment Entity, enables a RIC or REIT to make a self-determination under IRC § 860(e)(4).

When properly completed and filed with the IRS, Form 8927 serves as the taxpayer’s official statement attached to an amended or supplemental return for the relevant tax year. This establishes the official date of determination, allowing the entity to distribute deficiency dividends and claim the special deduction under Section 860.

Official IRS page: About Form 8927 (last reviewed January 23, 2026).

Why Form 8927 Matters: Understanding IRC Section 860 Deficiency Dividends?

Under IRC § 860, a QIE can deduct “deficiency dividends” paid after a determination that creates an adjustment for a prior taxable year. An adjustment includes:

  • Increase in taxable income (RIC or REIT)
  • Excess of net capital gain over capital gain dividends
  • Decrease in the dividends-paid deduction

Types of determinations under § 860(e):

  1. Court decision (final)
  2. Closing agreement (§ 7121)
  3. Agreement with the IRS
  4. Self-determination via taxpayer statement (Form 8927) attached to an amended/supplemental return — § 860(e)(4)

Key timing rules (per § 860(f) and (g)):

  • Deficiency dividends must be distributed within 90 days after the determination date.
  • Claim for the deduction (Form 976) must be filed within 120 days after the determination.
  • The determination date for self-determination is generally the date Form 8927 is mailed (see Rev. Proc. 2009-28, 2009-20 I.R.B. 1011, Section 4).

This process helps REITs and RICs avoid (or reduce) corporate-level tax while passing the economic burden to shareholders through additional distributions.

Who Must File Form 8927?

Only Qualified Investment Entities:

  • Regulated Investment Companies (RICs) filing Form 1120-RIC
  • Real Estate Investment Trusts (REITs) filing Form 1120-REIT

File when the entity wants to make a voluntary self-determination of an adjustment (e.g., after internal review or to resolve a potential issue proactively) rather than waiting for an IRS audit or court ruling.

Note: Form 8927 is not required for IRS-initiated determinations or court decisions.

Step-by-Step: How to Complete IRS Form 8927?

The form is short and straightforward (one page). Here’s exactly what to enter:

  1. Tax Year — Enter the calendar year or tax period (beginning and ending dates) to which the determination relates.
  2. Name of RIC or REIT — Full legal name.
  3. Employer Identification Number (EIN).
  4. Address — Complete mailing address. Use “C/O” if mail goes through a third party (accountant, attorney, etc.). If no street delivery, use P.O. Box.
  5. Service Center — Where the original tax return for that year was (or will be) filed.
  6. Signature — Authorized officer must sign under penalties of perjury, enter title, and date.

No additional schedules or financial data are required on the form itself—the supporting amended return or supplemental statement provides the adjustment details.

Where to file:

  • Internal Revenue Service
    P.O. Box 9941
    Mail Stop 4912
    Ogden, UT 84409

After Filing Form 8927: Next Steps for Deficiency Dividends

  1. Date of determination = Mailing date of Form 8927 (per Rev. Proc. 2009-28).
  2. Distribute qualifying deficiency dividends to shareholders within 90 days.
  3. File Form 976 (Claim for Deficiency Dividends Deductions…) within 120 days to claim the § 860 deduction.
  4. Pay any resulting tax (plus interest) or receive refund/credit as applicable.

Related forms:

  • Form 976 — Claim the actual deduction.
  • Form 1120-REIT or 1120-RIC — Amended return for the affected year (see instructions for both).
  • Instructions for Form 1120-REIT (2025) explicitly reference Form 8927 for establishing the determination date.

Benefits and Strategic Considerations

  • Avoids disqualification — Helps REITs maintain REIT status by correcting distribution shortfalls.
  • Tax efficiency — Allows deduction at the entity level; shareholders receive taxable dividends in the year received.
  • Interest savings — Compared to paying corporate tax outright, the timing can be advantageous (though interest runs on the full deficiency amount).
  • Proactive compliance — Self-determination gives control over timing versus waiting for IRS action.

Always consult Rev. Proc. 2009-28 for precise procedural details on self-determinations.

FAQs About IRS Form 8927

Is Form 8927 still current in 2026?
Yes. The December 2016 revision remains the latest; IRS listings confirm no newer version.

Can I e-file Form 8927?
No. It must be mailed to the Ogden address.

Do I need a tax professional?
Highly recommended. Determining the adjustment amount, preparing the amended return, and ensuring distributions qualify requires deep knowledge of Subchapter M and § 860 rules.

What if I miss the 90-day or 120-day windows?
The deduction may be disallowed. Strict timelines apply.

Where can I find more guidance?

  • IRS.gov About Form 8927
  • Instructions for Form 1120-REIT / 1120-RIC
  • IRC § 860 full text
  • Rev. Proc. 2009-28 (2009-20 I.R.B. 1011)

Conclusion: Protect Your REIT or RIC with Proper Use of Form 8927

IRS Form 8927 is the critical first step for QIEs exercising self-determination rights under Section 860(e)(4). Correctly filed, it unlocks the deficiency dividend deduction, helping REITs and RICs manage tax adjustments efficiently while complying with complex distribution requirements.

For the official form and instructions, visit IRS.gov/forms-pubs/about-form-8927 and download the PDF directly: https://www.irs.gov/pub/irs-pdf/f8927.pdf.

Tax rules are complex and facts-and-circumstances dependent. This article is for informational purposes only and is not tax or legal advice. Consult a qualified tax professional or attorney familiar with REIT/RIC taxation before taking any action.

Last updated February 2026 based on current IRS publications and forms.