EMIM (iShares Core MSCI EM IMI UCITS ETF (Accumulating)) is a conventional Ireland-domiciled UCITS fund. Such funds commonly meet a §1297 passive-income or passive-asset test even when they track emerging-market equities incl. small cap (alternate listing of EIMI); confirm the vehicle's structure and annual facts before filing Form 8621.
Because it is an accumulating share class it pays you nothing along the way, which makes the default §1291 treatment more expensive, not less.
No card · free draft · a CPA typically charges $1,200–$3,000+ for Form 8621 work; Atamatax is a flat $499.
If EMIM is confirmed as a PFIC, you may need a separate Form 8621. For supported inputs, Atamatax generates the official PDF with computed fields filled; review its notes and complete any remaining fields before filing outside Atamatax.
EMIM pays out nothing, so there may be no cash distribution to enter in a §1291 excess-distribution calculation while you hold. Separate annual Form 8621 reporting can still apply.
Mark-to-market (§1296) taxes the annual paper gain as ordinary income — and an accumulating fund sends you no cash to pay it with. Worth planning before you elect.
Same fund, other listings: EIMI · ISIN IE00BKM4GZ66. They are the same legal instrument; listing venue and currency do not change its entity classification.
EMIM tracks emerging-market equities incl. small cap (alternate listing of EIMI). Emerging-market funds tend to be held for long stretches and to be volatile in between — the profile the §1291 default punishes hardest, since the deemed tax on each earlier year of the holding period carries an interest charge that runs until you file.
The foreign exposure underneath is not itself the test. The conventional Ireland-domiciled UCITS fund and its passive income and assets are the relevant issuer-level facts. A US-organized emerging-markets ETF is not a foreign corporation and therefore sits outside the PFIC definition. If you hold the other line instead — EIMI — the entity-classification analysis is unchanged: it is the same legal instrument under another listing.
EMIM pays you nothing. The dividends from the underlying shares are reinvested inside the fund instead of hitting your account. Under the default §1291 rules, there may be no cash distribution to test as an excess distribution while you simply hold, while a later disposition can still trigger the allocation and interest-charge regime. Separate annual Form 8621 reporting can also apply during the holding period.
The whole bill then arrives at once. When you sell, the entire gain is allocated rateably across every day you owned EMIM; each prior year's slice is taxed at that year's highest ordinary rate, and an interest charge runs from each of those years through to the filing date. An accumulating share class is where §1291 does the most damage, because the longer you held quietly, the longer the interest has been running.
Two knock-ons worth planning around. A mark-to-market election under §1296 taxes the annual paper gain as ordinary income — but EMIM distributes no cash, so you have to fund that tax from somewhere else every year. And a QEF election under §1295 requires a PFIC Annual Information Statement from the fund; if iShares does not produce one for this share class, QEF is not actually available to you no matter how much better it looks on paper.
A word on which line this is. EMIM shares ISIN IE00BKM4GZ66 with EIMI: one instrument, several tickers. Your broker will show whichever line you bought, and that is the one to report — but it is a single PFIC position, so it gets a single Form 8621 no matter which ticker the statement prints.
The QEF route for EMIM depends on BlackRock/iShares issuing a PFIC Annual Information Statement covering the year — the ordinary-income-and-capital-gain breakdown §1295 requires. Ask for it in writing before you file rather than after: a QEF election made without the statement to support it is not one you want to be defending later.
EMIM is the iShares Core MSCI EM IMI UCITS ETF (Accumulating), ISIN IE00BKM4GZ66. Match the ticker — and the ISIN, where your statement shows one — to this line before reading the mechanics above as yours.
EIMI is the same security as EMIM under another ticker — the same ISIN, IE00BKM4GZ66. Whichever line your broker shows, EMIM and EIMI are one holding for Form 8621: one fund, one holding period, one election history.
One other emerging-market equity fund in this registry raises the same question as EMIM: VFEM. EMIM follows an MSCI index; VFEM follows FTSE. The §1297 analysis does not change from one issuer to the next, and each fund is its own PFIC — its own Form 8621, holding period and election history. What does change is the share class, and whether the issuer publishes a PFIC Annual Information Statement for it.
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.
This is a screening assessment based on published vehicle facts and the statutory tests—not a classification based on domicile alone, and not individualized tax, legal, or investment advice — see our methodology (IRC §1297 et seq.). Confirm your specific situation with a licensed professional.
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.
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