If you are a US person holding non-US ETFs, mutual funds or other pooled investments through a foreign brokerage, those holdings are potential PFICs — and a reporting trigger can mean a separate Form 8621 for each holding. Atamatax helps with classification inputs and supported calculations, then generates reviewable draft forms and worksheets.
By Danilson Ramos · Founder, Atamatax
Published · Updated
Free PFIC scan · Pay only to generate the package · Sources cited on every figure
The short answer
A PFIC — passive foreign investment company — is a non-US corporation that meets either of two tests under §1297: an income test (75% or more of gross income is passive) or an asset test (50% or more of assets produce, or are held to produce, passive income). Conventional non-US pooled investment companies commonly meet one or both tests because of their passive income and assets. The legal vehicle and annual facts still control.
That sweeps in the ordinary investment products a European, Swiss or Asian broker sells: UCITS ETFs, local mutual funds, SICAVs, unit trusts, investment trusts and many fund-based pension or savings wrappers. PFIC analysis applies at the foreign-vehicle level, not directly to the portfolio companies. A conventional Ireland-domiciled UCITS ETF tracking the S&P 500 is therefore a strong PFIC candidate, but domicile alone is not the statutory test.
Individual foreign stocks are generally not PFICs. The issue is funds and other pooled vehicles organised outside the United States.
The consequence is reporting: generally one Form 8621 per PFIC, per year, and without a QEF or mark-to-market election the default §1291 regime applies — gain/excess distribution taxed at the highest ordinary rate for each allocated year, plus an interest charge.
The full PFIC guide
The form each PFIC generally needs, who has to file it, and how to produce it.
The three regimes — and why the one you fall into by default is the expensive one.
The specific products that turn out to be PFICs for US persons.
Free tools that answer the question for your actual portfolio.
What PFIC exposure looks like at the platforms US expats actually use.
PFIC rules against the local investment products people actually own.
Before you hire anyone: what actually drives the bill on a PFIC return.
What the price covers
Per-form professional preparation
from $170/ Form 8621
Bright!Tax’s published starting fee for a PFIC with no distributions (checked October 2026; fee schedule). A firm prepares, advises and signs; fees rise with distributions and the rest of the return.
Atamatax · PFIC
$499/ tax year
Up to 25 Form 8621s, QEF / MtM / §1291 per holding, domicile classification, FBAR and 8938 checks — one flat price. On-screen draft free; pay to generate the package, which you or your preparer review, sign and file.
From 3 PFICs the per-form starting fee passes the flat price. The two buy different things — compare the scope with the price. General information, not tax advice.
How it works
Paste or import your holdings into the free PFIC checker. We apply the available domicile and security signals, flag likely PFICs for your review, and explain uncertain classifications — no card required.
Compare QEF, mark-to-market and §1291 side by side for each fund, with the §1291 estimator to size the cost. Bulk-apply a method to similar funds.
Generate the paid package to receive a Form 8621 for each supported PFIC — a pre-filled official PDF only for a tax year whose official form is integrated and released, otherwise a worksheet with every figure mapped to the form's lines (up to 25), plus mapped 1040 and Schedule worksheets. Review the package and complete every field it identifies before filing outside Atamatax.
Start with the free tools
Would you rather have the forms prepared than use the software? PFIC preparation with a written scope and a fixed quote — who prepares, reviews, signs and files is set out before you pay.
Understand the rules first
PFIC software · FAQ
Is your fund a PFIC?
These conventional non-US UCITS funds commonly meet a PFIC test, while the gold ETC entries require a legal-wrapper review. Check the specific vehicle, then determine whether Form 8621 applies to your facts.
All funds in one table — issuer, ISIN, share class, whether the issuer publishes a PFIC Annual Information Statement, and the date each was verified. Sortable, with a CSV download.
By country
The classification is the same everywhere — a non-US pooled fund is a PFIC wherever you hold it — but which local products you're likely holding, and what to check first, differs by country.
From one fund to the whole case
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
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.
Free preliminary result · a few questions
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.
Atamatax · PFIC filing
Considering a foreign fund or pension product? Screen the product before buying it.
Before you buyPrimary 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.