Skip to main content
Next expat filing deadlineCheck my situation
PFIC · Form 8621

PFIC tax filing for US expats.
From holdings to Form 8621.

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.

Free PFIC scan · Pay only to generate the package · Sources cited on every figure

The short answer

What is a PFIC?

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.

Diagram: a PFIC gain of $45,000 on a fund held from 2021 to 2025 is allocated $10,000 to each full year and $5,000 to the year of sale; the prior-year slices are taxed at that year's top ordinary rate plus interest, the current-year slice as ordinary income.
How the §1291 default treats a gain when no election is in place. Illustrative amounts; the mechanism is IRC §1291(a) and (c).

The full PFIC guide

Everything a US person with foreign funds has to work through.

The whole reason most expats are here

A CPA charges ~$3,200 for the same Form 8621s. We charge $499.

Traditional CPA

~$3,200/ return

Per-form billing, hourly add-ons for each PFIC, weeks of back-and-forth — and you still review every number yourself.

Atamatax · PFIC

$499/ return

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.

CPA figure is an illustrative market estimate for a multi-PFIC expat return, not a quote. Your costs vary. This is general information, not tax advice.

How it works

From a pile of foreign funds to a reviewable draft in three steps.

01

Scan your funds

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.

02

Choose a method per holding

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.

03

Get a reviewable Form 8621 draft

Generate the paid package to receive one official Form 8621 PDF per supported PFIC input (up to 25), plus mapped 1040 and Schedule worksheets. Review the package and complete every field it identifies before filing outside Atamatax.

PFIC software · FAQ

Honest answers before you start.

What does PFIC reporting mean for US expats?
A U.S. person generally files a separate Form 8621 for each PFIC when one of the form’s filing circumstances applies; exceptions and indirect-ownership rules can change the result. Tax treatment may fall under §1291 or a valid QEF or mark-to-market election, each with its own requirements. An expat’s foreign brokerage account is not itself a PFIC; a pooled investment inside it may be. FBAR and Form 8938 are separate account or asset reporting tests. Certain missing international information returns can affect the limitations period under §6501(c)(8), subject to the statute’s rules.
Do you e-file the return for me?
Atamatax generates a draft PDF package: an official Form 8621 PDF for each supported PFIC input, plus mapped 1040 and supporting-schedule worksheets. You or your CPA review the notes, complete any remaining fields, and file it with the instructions provided.
What does $499 actually cover?
A draft expat return package with PFIC analysis: mapped Form 1040 and Schedule B/D figures, up to 25 Form 8621 PDFs for the methods and inputs the engine supports, fund-domicile classification, Form 8938 (FATCA) and FBAR threshold checks, and Form 1116 mapping for the foreign tax credit. The package calls out items that still need review or completion. One flat price, no per-form add-ons.
What if I have more than 25 PFICs?
The $499 tier covers up to 25 supported Form 8621 drafts. If you hold more, get in touch before purchase to confirm whether the product fits your case.
Does holding a fund inside a foreign pension or insurance wrapper remove the Form 8621 requirement?
This is genuinely contested, and a page that answers it flatly in either direction is overstating what is known. The funds themselves are unaffected by the wrapper: a UCITS ETF is a non-US pooled vehicle whether an ISA, an assurance-vie, a SIPP or a Pillar 3a account holds it. What is argued about is whether the wrapper changes who the PFIC shareholder is, and whether a tax-favoured retirement arrangement takes the holding outside the shareholder rules. Some arrangements have specific relief and most do not, and the answer turns on the arrangement's own terms rather than on what it is called locally. Atamatax identifies the wrapper and the holdings, states the assumption it is running under, and routes an unsettled wrapper question for professional review rather than picking the answer that produces less work.
Which method should I pick for each fund?
Eligibility and timing matter. A QEF election generally needs the PFIC’s Annual Information Statement and must meet election rules; mark-to-market is available only for stock that meets the qualified-marketability requirements; §1291 may apply when no effective alternative election governs. Prior years, late elections, holding history and available records can change the analysis. Our method guide and estimator are educational screens, not a recommendation for your facts.

Is your fund a PFIC?

The UCITS ETFs US expats ask about most.

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.

By country

How PFIC works from where you live

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

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.

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.

Atamatax · PFIC filing

See your Form 8621 count first. Pay $499 only when you generate the package.

Considering a foreign fund or pension product? Screen the product before buying it.

Before you buy

Authorities cited

  • IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
  • IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • IRC §1295 — IRC §1295 — Qualified Electing Fund (QEF) election
  • IRC §1296 — IRC §1296 — Mark-to-market election for marketable PFIC stock
  • IRC §1298 — IRC §1298 — PFIC special rules (attribution, indirect ownership)
  • IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF

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.

Get started free