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8865 vs 5471

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    8865 vs 5471

    I have a client who is a US citizen married to a UK citizen and they live in the UK. They jointly own 50% each of a PFIC (Passive Foreign Investment Company formed as a United Kingdom limited company)

    My questions is: Can their PFIC file an 8865 as a partnership rather than file a 5471 informational return for a foreign corporation? I was told several years ago that there was a check-the-box election for this option. If so, does anyone know which form it is on?
    Thanks very much for any guidance!
    Paula
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