Form 8621 for PFICs in Switzerland

Why Americans in Switzerland end up with multiple Forms 8621 — from UCITS ETFs to a fund-based Pillar 3a — and how to produce them.

For Americans in Switzerland, Form 8621 is rarely a one-off. Swiss and European funds — UCITS ETFs, Swiss-domiciled funds, and the funds inside a fund-based Pillar 3a — are PFICs, and each one is its own Form 8621 every year.

Where your Swiss PFICs come from

UCITS ETFs (Ireland/Luxembourg) bought because your broker blocked U.S.-domiciled ETFs.
Swiss-domiciled funds (ISIN CH…).
The funds inside an invested Pillar 3a (VIAC, finpension, Frankly).
A fund-based vested-benefits account.

U.S.-domiciled ETFs are not PFICs — if you hold those (e.g. via Interactive Brokers), there's no Form 8621 for them.

How many forms, and the de minimis exception

One Form 8621 per PFIC per year. If your aggregate PFIC value is $25,000 or less ($50,000 MFJ) with no distributions or dispositions, the reporting exception may apply — check the current instructions.

Producing the forms

The default §1291 worksheet allocates each excess distribution or gain across your holding period and adds the interest charge — the calculation a CPA typically charges $150–$200 per form to do. Build it with the calculator, then check every Swiss holding with the checker.

Find and draft your Swiss Forms 8621

Check which Swiss holdings are PFICs, then build the §1291 worksheet. Atamatax is tax-preparation software, not a CPA firm, and this is not individualised tax advice.

Check my Swiss holdings for PFICs

Educational estimate, not tax advice. Confirm each holding's PFIC status and your filing obligation with the current IRS instructions or a qualified professional.

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

Frequently asked questions

Is my Swiss or UCITS fund a PFIC that needs Form 8621?

Non-U.S.-domiciled funds (UCITS from Ireland/Luxembourg, Swiss funds) generally are PFICs needing Form 8621; U.S.-domiciled funds are not. It turns on domicile, so check each holding.

Does my Pillar 3a need Form 8621?

An invested 3a holds non-U.S. funds that are generally PFICs, each its own Form 8621; a cash 3a holds no funds, so no Form 8621 (though the account is still reportable).

How much do multiple Forms 8621 cost at a firm?

Expat firms typically charge $150–$300 per form, so several Swiss funds means several fees. Self-serve software is a flat price regardless of the number of forms.