TP is filing 2019 MFJ return and has PFICs. The total value of PFICS on December 31, 2019 was USD33,000. It is my understanding that if PFIC’s value does not exceed USD50,000 (de minimis holdings exception), MFJ taxpayer can rely on this reporting exception but my reading of the Form 8621 instructions (page 5) seems to indicate that exception only for Part 1 of Form 8621 not the entire Form 8621 (A shareholder is not required to complete Part I with respect to a specific section 1291 fund). Any idea?

Thank you for your time and comment.