@Nkm171964 on your point 4 about form 8621 -- the easiest path here is to file the form 8621 and choose Mark-To-Market. I say this because even though most participants are small potatoes in the scheme of things --- 1. it is hard to get all the details consistently to support the other two choices of "excess distribution " and QEF etc.
2. Mark-To Market essentially means this is a deemed sale each year and matching to FMV of the shares held .
Granted this seems unfair but PFICs rules are draconian and in an effort to discourage US persons from shifting incomes elsewhere. But it is the little guy that gets crushed ion the process.
The advantage of this is that since this MTM -- your basis also changes along the way. Thus the last bite may be more palatable. The bad part of this is that while US taxes are reduced the bite from India does not move accordingly. Thus when finally disposed of, there may be large Foreign Tax, very little US tax and therefore Foreign Credit may be lost ( because no matter the accumulated / carried forward Foreign Tax Credit, the allowable is no more than the US tax on that foreign income. It is a lose -lose proposition.
That is my understanding of the situation.
Is there more I can do for you ?
pk
