Skip to main content
Next expat filing deadlineCheck my situation

Broker · Europe

DEGIRO & PFICs for US persons

DEGIRO's universe is UCITS by construction — which makes nearly every fund on it a PFIC for a US taxpayer. What to check before you file.

By Danilson Ramos · Founder, Atamatax

Published July 2026 · Updated September 2026

Your situation, in five answers

What happened
You hold, or held, funds or ETFs in a DEGIRO account while being a US person — often an account opened before you became one.
Why it matters
DEGIRO's shelf is European by construction, so the ordinary thing to own there is exactly the thing US tax treats worst. Owning it is not a violation; not reporting it is the problem.
What it could trigger
Each UCITS ETF or European fund may be a PFIC with its own Form 8621 every year under the §1291 default; the account itself may need the FBAR and Form 8938. The cash sweep fund can be a PFIC too.
What you need
DEGIRO's positions export with an ISIN per holding, your purchase dates and cost per lot, any distributions, and the account's maximum and year-end value for every year you held it.

Check it for your own holding

Could this investment be a PFIC?

Two questions and, if you have it, the ticker or ISIN. The read is immediate, nothing you enter leaves this page, and it names what would settle the rest.

Free, no account, nothing you answer leaves this page. Open the full portfolio scanner

What is it?

Screened against the fund registry on this page. It is never sent anywhere.

A screen. Whether a fund is a PFIC turns on its own annual income and asset facts under §1297; the read above says how far your answers go and what would settle the rest.

DEGIRO is one of Europe's largest retail brokers — and for a US person, one of the most reliable ways to accumulate PFICs, because its fund universe is European by construction.

Can a US person use DEGIRO?

DEGIRO's onboarding generally does not accept US persons (its account terms and W-8 process screen for US status — confirm current policy with DEGIRO). In practice the US persons who hold DEGIRO accounts are usually people who opened one before becoming a US person, accidental Americans, or green-card holders who didn't flag their status. The tax rules below apply to all of them.

Why almost everything at DEGIRO is a PFIC

EU PRIIPs rules effectively block European retail brokers from selling US-domiciled ETFs (no KID document), so the ETFs DEGIRO offers are UCITS funds domiciled in Ireland or Luxembourg. For a US taxpayer each one is generally a PFIC: one Form 8621 per fund per year, and the punitive §1291 default regime on gains and large distributions unless you elect otherwise.

Holding at DEGIROPFIC?Typical filing
UCITS ETF (ISIN IE, LU…)LikelyForm 8621 each year
European mutual fund (ISIN NL, DE, FR…)LikelyForm 8621 each year
Individual company sharesNoReport the account
Cash balance / money-market sweep fundThe sweep FUND is likely a PFICCheck the fund's ISIN
The detail people miss: DEGIRO historically parked uninvested cash in a money-market fund rather than a bank balance — a non-US fund that is itself likely a PFIC. Check your statements for a fund ISIN on the cash line.

FBAR and Form 8938

A DEGIRO account is a foreign financial account: it counts toward the $10,000 FBAR aggregate and toward the Form 8938 thresholds. Export your annual statement (positions + cash, with maximum and year-end values) — that's the data both forms need.

  • Export the annual report / positions overview (CSV) — ticker, ISIN, quantity, year-end value.
  • Check each ISIN prefix: US… is not a PFIC; IE/LU/NL/DE/FR… likely is.
  • Note each account's maximum balance during the year for the FBAR.
  • If you hold UCITS funds, model the §1291 cost before selling anything.

What information matters

Whether a DEGIRO holding is a PFIC is settled by what the fund is, not by where you bought it. Before any tool or preparer can go further, four things have to be in hand for each fund: its ISIN (the issuer and, usually, the domicile), the purchase date and cost of each lot (the §1291 rules allocate a gain across every day you held it), any distributions it paid in the year, and the account's maximum and year-end value for every year the position existed — not only the year you are filing now. DEGIRO's positions and transactions exports carry all of it; the annual statement alone does not show lots.

Why the number of funds and years matters

Form 8621 is filed per PFIC, per year. Three UCITS ETFs held for four unreported years is not one form; it is twelve, and each one carries its own §1291 arithmetic when a fund was sold or paid a large distribution. That count is what decides the shape of the work. Atamatax's PFIC package prepares up to 25 Forms 8621 inside one return for a flat $499; a portfolio above that, or one where the earlier years were never filed at all, is a scoped case rather than a self-serve return.

When DIY software stops being enough

Mainstream consumer software does not prepare Form 8621 at all — TurboTax cannot file it. Purpose-built software can, when the holdings are identified, the lots and distributions are known and the return years are otherwise current. It stops being enough when several prior years are unfiled (that is a catch-up question before it is a form question), when cost basis is missing for lots bought years ago, or when an election decision — QEF, mark-to-market or neither — has to be made consistently across many funds and years. Those are the cases to scope before buying anything.

What Atamatax can evaluate

Free, on this site: screen each ISIN for PFIC indicators, run the whole export through the portfolio analyzer, and estimate how many Forms 8621 the holdings imply. Paid: prepare those forms inside the return, with the §1291 allocation shown. Not on offer from software: a legal determination that a specific fund is or is not a PFIC, any view on non-willfulness, or DEGIRO's own policy on US persons — those are the fund's annual facts, a legal question and the broker's terms respectively.

Check your DEGIRO holdings before you file

Paste your ISINs — the free checker screens each holding for PFIC indicators and names the next record to confirm. Run the whole positions export through the analyzer to see how many Forms 8621 the portfolio implies. This is general information, not individualised tax advice.

Broker policies change — confirm current DEGIRO terms with DEGIRO. Atamatax provides preparation software and educational estimates, not individualised tax, legal, or investment advice.

From one fund to the whole case

What does your PFIC situation actually require?

Four questions — how many funds, for how long, whether Forms 8621 were ever filed, whether the returns are current — and a route into the preparation that fits, with what it costs. Nothing you answer leaves this page.

Free, no account, nothing you answer leaves this page. Open the full portfolio scanner

How many non-US funds or ETFs do you hold?

Count each fund, not each account. Funds inside a wrapper (ISA, TFSA, Pillar 3a, super) count.

For how many tax years have you held them?

Including the current year. A fund bought in 2023 and still held is three years.

Has a Form 8621 been filed for them before?
Are your US tax returns themselves up to date?

A routing read, not a determination. Whether a fund is a PFIC, whether an exception applies and what a prior year needs are established when the holdings are screened; the route above says where that happens and what it costs.

Authorities cited

  • IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
  • IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
  • 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
  • FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
  • IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

Frequently asked questions

Can I open a DEGIRO account as an American?#
DEGIRO's onboarding generally screens out US persons, so most US-person holders opened the account before acquiring US status. If you already hold an account, the PFIC and FBAR questions on this page apply regardless of how it was opened. Confirm current policy with DEGIRO.
Are my DEGIRO ETFs PFICs?#
Generally they are strong PFIC candidates: DEGIRO's conventional UCITS funds commonly meet a §1297 income or asset test. The broker and exchange do not change the vehicle's structure; use the ISIN as a clue, then confirm the issuer and annual facts. Individual operating-company shares are not classified merely because they trade abroad.
Do I report DEGIRO on the FBAR?#
Yes if your combined non-US accounts exceeded $10,000 at any point in the year — the DEGIRO account counts toward that aggregate whether or not anything in it is a PFIC.
How many Forms 8621 will a DEGIRO account need?#
One per PFIC per year, as a rule: the number of UCITS funds you held multiplied by the years you held them, plus the cash sweep fund if it was a fund. Atamatax's PFIC package covers up to 25 forms in one return; above that, or with unfiled prior years, the work is scoped as a case first.
I have held DEGIRO ETFs for years and never filed Form 8621. What now?#
It depends on whether the returns for those years were filed. A filed return that left out Form 8621 is generally corrected by amending it; years that were never filed are a catch-up question, where the Streamlined Foreign Offshore Procedures may apply to a non-willful US person abroad. Sort the years first, then the forms. This is general information, not individualised advice.

Related guides

Preparation · price before you start

If you want the Forms 8621 prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

  1. Your returns are up to date and the non-US funds are the complication

    PFIC Portfolio · $499 · Self-serve preparation

    PFIC Portfolio covers portfolios of four to twenty-five likely PFICs, with a Form 8621 drafted per fund.

    What arrives, who prepares and checks it, and who files

    Everything in Simple plus up to 25 supported Forms 8621 with QEF / mark-to-market / §1291 inputs per holding, fund-domicile classification with confidence shown, and the assumption log — for one tax year.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Prepare my PFIC portfolio
  2. You already work with an accountant who files for you

    CPA Export · $199 · Accountant handoff

    You already have an accountant. CPA Export gives them the per-fund PFIC screen with its reasons and the threshold arithmetic, so the fund question is settled before the return is drafted.

    What arrives, who prepares and checks it, and who files

    A PDF hand-off for an accountant: the holdings and PFIC classification table, the potential Form 8621 workload, FBAR/Form 8938 threshold logic, worksheets mapped to form lines, and the assumption log — for one tax year.

    The engine builds the PFIC analysis and the worksheets from the entries you confirm. Your accountant prepares the return from them.

    Nobody at Atamatax reviews the export before you download it. Your accountant checks it — every classification and figure carries the assumption behind it.

    Your accountant files the return, or you do; the FBAR is filed on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Build my CPA Export
  3. Returns, FBARs or Forms 8621 are missing for earlier years

    Streamlined Investor · $2,200 · Scoped by hand

    The catch-up years include non-US funds or a personal foreign plan, so each back year needs PFIC work as well as the return and the FBAR.

    What arrives, who prepares and checks it, and who files

    A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official PDFs for the current filing year), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.

    A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.

    A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote
  4. More than twenty-five funds, or the fund facts are incomplete

    Confirm the scope before choosing a package · Free to ask

    More than twenty-five likely PFICs is past the included limit of every package; the scope is confirmed by hand before a price is named.

    What arrives, who prepares and checks it, and who files

    Free to ask. A person reads the facts and says whether Atamatax can take the case, and which route it would be.

    A person at Atamatax reads the facts before any route is offered.

    See whether Atamatax can take the case

When a professional's judgment is needed. A person reads the facts before any package is sold when the fund screen cannot finish, when there are more than twenty-five likely PFICs, or when a late QEF or mark-to-market election is in question — whether a late election can still be made turns on the facts and is a professional's call.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com get a reply within one business day. Who does what in each route.

Free preliminary result · a few questions

Build your PFIC filing map

Know what PFIC reporting means for your own holdings: how many Forms 8621 are likely, whether the year produced tax or only reporting, and what else your situation pulls in.

Build my PFIC filing mapNo signup. Answers stay yours.

Your next step · free

Is the fund you hold a PFIC?

Search by ticker, ISIN or name. Where the domicile settles it the result says so; where it does not, it says that instead of guessing. Free, no account.

Get started free