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Topic · Switzerland

PFICs & Swiss Investments for U.S. Persons

Why Swiss and European funds are often PFICs, what Form 8621 means, and how to check your holdings before filing.

By Danilson Ramos · Founder, Atamatax

Published June 2026 · Updated September 2026

Part of the Switzerland desk — every US tax topic for Switzerland in one place.

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.

One of the biggest surprises for Americans investing in Switzerland is the PFIC regime. A PFIC (passive foreign investment company) is, in practice, most non-U.S. pooled funds — and U.S. tax treats them unfavorably.

Why a Swiss or European ETF is usually a PFIC

PFIC status turns on the fund's structure and non-U.S. domicile, not on what it invests in. A Switzerland- or Ireland-domiciled ETF — even one tracking U.S. stocks — is generally a PFIC for a U.S. person who holds it.

Individual stocks are generally not PFICs. The issue is funds and ETFs organized outside the U.S.

What a PFIC means at filing time

  • Each PFIC generally needs its own Form 8621.
  • Without an election, the default rules can be punitive.
  • Elections (QEF, mark-to-market) change the treatment but have requirements.

What to check

List every fund/ETF you hold, including inside an invested pillar 3a. The free Tax Risk Check flags whether a PFIC review is likely worthwhile for you.

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 §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
  • 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

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

Is an S&P 500 ETF I bought in Switzerland a PFIC?#
Yes — a non-U.S.-domiciled fund (e.g. Irish or Swiss UCITS) is generally treated as a PFIC for a U.S. person even though it holds U.S. stocks. A U.S.-domiciled ETF is not a PFIC.
Do I really have to file a Form 8621 for each fund?#
Yes — each PFIC generally requires its own Form 8621, with a per-fund election decision. This is exactly the work Atamatax is built to handle.
Is my pillar 3a a PFIC?#
The wrapper alone does not establish PFIC status. An invested 3a may hold non-US pooled funds that meet §1297; identify each holding and its issuer. A cash balance does not itself constitute a fund share. Form 8621 has separate holder-level triggers and exceptions.

Related guides

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