@itonewbie Thanks for your time and comment.

TP met all the 3 conditions spelled out in 1.1298-1(c)(2): threshold met as PFIC value is less than $50,000 on December 31, 2019, TP did not have excess distribution in 2019 (2019 distribution is less than 2018 distribution, 2018 is the year PFIC was acquired) and no QEF election has been made in 2018 and 2019.

Therefore, TP does not need to file 2019 Form 8621. Is this correct?

The IRS Form 8621 page 5 instruction on the de minimis exception is misleading as it waiving only completion of part 1 of Form 8621.  Is this right?