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Synthetic example — not a real client. Every name, date and figure below is invented. The structure, the rules and the pipeline are exactly those of a live export; the shared case it comes from is the same invention.

For CPAs, EAs & international tax firms

What a professional hand-off contains.

One client, one file: the facts they confirmed, the analysis the engines produced, every assumption and open item, the trace behind each figure, and the formats it ships in. Read it top to bottom in the order you would review it.

Export version 1.2Engine 2026.09.15 · PFIC 2026.08.26 · FX 2026-02-24+2026-08-25

Sample export (JSON) · CSV tables · the case it comes from

1 · Input

What the client confirmed

Marco Example

Residence
CH
Citizenships
CH, US
US status
citizen
TIN
ssn
Work
3 tax years · 2 foreign accounts to report · 2 holdings to screen (2 likely PFICs, 1 without purchase records)

This case involves additional work because:

  • 3 tax yearsEach year is its own return, with its own income figures, its own exchange rates and its own set of forms.
  • 2 foreign accountsEach account is reported with its yearly maximum, its institution and who holds it.
  • 2 holdings to screen2 holdings screened as a likely PFIC, and each one generally needs its own Form 8621 for each year it was held.
  • 1 without purchase recordsThe purchase date and cost of each lot are rebuilt from statements before the §1291 allocation can be computed.
  • 3 countriesIncome, tax paid and treaty positions are worked per country, and the foreign tax credit is computed per category.

Tax years in scope

YearReturnFBARForms in scope
2025not_filedthreshold exceededForm 1040, Form 8621, FBAR (FinCEN 114), Form 8938, Form 1116, Schedule B
2024not_filedthreshold exceededForm 1040, Form 8621, FBAR (FinCEN 114), Form 8938, Form 1116, Schedule B
2023open questionthreshold exceededForm 1040, Form 8621, FBAR (FinCEN 114), Form 8938, Form 1116, Schedule B

Foreign accounts (2)

  • UBS · CH · bank

    2024: $70,800.00 (extracted) · 2025: maximum not on record (estimated)

  • Swissquote · CH · brokerage

    2024: $84,000.00 (extracted)

Holdings (2)

  • Vanguard FTSE All-World UCITS ETF · IE00B3RBWM25 · IE · Swissquote

    cost basis on record · purchase history on record · not sold · distributions received

  • Swisscanto (CH) Index Equity Fund World · CH0117044708 · CH · Swissquote

    no cost basis on record · no purchase history · not sold · no distributions

Documents (3)

  • ubs-2024-year-end.pdf · 2024 · accepted · evidences 1 item
  • swissquote-2024-statement.pdf · 2024 · accepted · evidences 3 items
  • ch-tax-assessment-2024.pdf · 2024 · pending_review

2 · Analysis

What the engines produced

PFIC screen, per holding

A screening status is a classification from the instrument's identity, with its rule and confidence next to it. Only a reviewer-verified determination establishes a PFIC conclusion.

HoldingScreenConfidenceRuleDetermination
Vanguard FTSE All-World UCITS ETFconfirmed_pfichighpfic-screen@2026-08-26.4screened_likely_pfic (engine)

Screened as a registry-confirmed PFIC from its identity (canonical registry). A screen is not a tax determination; a person verifies it before any form is prepared.

Swisscanto (CH) Index Equity Fund Worldlikely_pficmediumpfic-screen@2026-08-26.4screened_likely_pfic (engine)

Screened as a likely PFIC from its identity (isin domicile and structure). A screen is not a tax determination; a person verifies it before any form is prepared.

Form 8621 workload

6

estimated forms · 2 likely PFICs × 3 years

Method section1291 · 1 without basis · complexity high

  • · 6 holding-year reviews may be needed before any exception is applied.
  • · 3 tax years require year-specific facts and elections to be checked.
  • · Purchase dates or cost basis are missing and must be reconstructed or reviewed.
  • · Sales or distributions may require transaction-level calculations.

FBAR threshold, per year

  • 2025 · — vs $10,000.00 · no data

    2 of 2 account(s) have no recorded maximum for 2025; the aggregate is a lower bound and the threshold cannot be ruled out.

  • 2024 · $154,800.00 vs $10,000.00 · threshold met

    The recorded maxima alone exceed $10,000.

  • 2023 · — vs $10,000.00 · no data

    2 of 2 account(s) have no recorded maximum for 2023; the aggregate is a lower bound and the threshold cannot be ruled out.

  • 2022 · — vs $10,000.00 · no data

    2 of 2 account(s) have no recorded maximum for 2022; the aggregate is a lower bound and the threshold cannot be ruled out.

  • 2021 · — vs $10,000.00 · no data

    2 of 2 account(s) have no recorded maximum for 2021; the aggregate is a lower bound and the threshold cannot be ruled out.

  • 2020 · — vs $10,000.00 · no data

    2 of 2 account(s) have no recorded maximum for 2020; the aggregate is a lower bound and the threshold cannot be ruled out.

Form 8938 threshold, per year

  • 2025 · — vs $200,000 / $300,000 · no data

    No account values recorded for the year.

  • 2024 · $154,800.00 vs $200,000 / $300,000 · below threshold

    Recorded account values stay below both lines; assets outside reported accounts are not included.

  • 2023 · — vs $200,000 / $300,000 · no data

    No account values recorded for the year.

3 · Assumptions & open items

What rests on a default, and what is still open

Assumptions (4)

  • Vanguard FTSE All-World UCITS ETF · 2024: No election is on record for this instrument. The §1291 default regime is assumed; a prior QEF or mark-to-market election must be attested before it is applied.
  • Vanguard FTSE All-World UCITS ETF · 2025: No election is on record for this instrument. The §1291 default regime is assumed; a prior QEF or mark-to-market election must be attested before it is applied.
  • Swisscanto (CH) Index Equity Fund World · 2024: No election is on record for this instrument. The §1291 default regime is assumed; a prior QEF or mark-to-market election must be attested before it is applied.
  • Form 8938 assets: Securities are treated as held within the reported brokerage accounts; their values are not added a second time.

Unresolved items (12)

  • MISSING CRITICAL · security:s2

    Swisscanto (CH) Index Equity Fund World: no purchase date or quantity is on record, so the holding period cannot be established.

    Question: When did you first buy Swisscanto (CH) Index Equity Fund World, and how many units?

  • MISSING CRITICAL · security:s1 · 2025

    Vanguard FTSE All-World UCITS ETF: no value at 31 December 2025.

    Question: What was Vanguard FTSE All-World UCITS ETF worth on 31 December 2025?

    Document: Year-end 2025 statement

  • MISSING CRITICAL · account:a1 · 2025

    UBS: the highest balance during 2025 is not on record; the FBAR line for that year cannot be completed.

    Question: What was the highest balance of your UBS account at any point in 2025?

    Document: 2025 statements for UBS showing the peak balance

  • MISSING CRITICAL · account:a2 · 2025

    Swissquote: the highest balance during 2025 is not on record; the FBAR line for that year cannot be completed.

    Question: What was the highest balance of your Swissquote account at any point in 2025?

    Document: 2025 statements for Swissquote showing the peak balance

  • MISSING CRITICAL · account:a1 · 2023

    UBS: the highest balance during 2023 is not on record; the FBAR line for that year cannot be completed.

    Question: What was the highest balance of your UBS account at any point in 2023?

    Document: 2023 statements for UBS showing the peak balance

  • MISSING CRITICAL · account:a2 · 2023

    Swissquote: the highest balance during 2023 is not on record; the FBAR line for that year cannot be completed.

    Question: What was the highest balance of your Swissquote account at any point in 2023?

    Document: 2023 statements for Swissquote showing the peak balance

  • MISSING CRITICAL · tax-year:2023 · 2023

    Whether a 2023 return was filed is unknown; the Streamlined return set cannot be fixed until it is.

    Question: Was a U.S. return filed for 2023?

  • MISSING USEFUL · account:a2

    Swissquote: whether you own the account or only sign on it is not recorded.

    Question: Do you own the Swissquote account, or do you only have signature authority over it?

  • MISSING USEFUL · person:00000000-0000-4000-8000-0000000000ac

    Purchase records complete — not yet answered.

    Question: Do you have records of what you originally paid for them, and when?

  • MISSING USEFUL · requirement:r2

    Complete broker and fund statements: not yet provided.

    Question: Can you upload: Complete broker and fund statements?

    Document: Complete broker and fund statements

  • OPTIONAL · account:a2

    Swissquote: opening date not recorded.

    Question: Roughly when was the Swissquote account opened?

  • OPTIONAL · requirement:r3 · 2024

    Foreign tax records for 2024: provided, awaiting a person's check.

    Question: Foreign tax records for 2024 — no action needed from you right now.

4 · Workpaper trace

Where every figure came from

Every fact carries its source — a document, a client statement, an engine rule, a staff note or a default — and every computed year carries the calculation version and an input fingerprint, so a reviewer can tell what changed and why.

Calculation trace (1)

HoldingYearMethodCalc. versionForm rev.FingerprintReviewer
Vanguard FTSE All-World UCITS ETF202412912026.08.2620243f9c1e7a…pending

Source trace (first 12 of 48)

  • Vanguard FTSE All-World UCITS ETF · Lot acquired 2021-03-15200 units · basis recordeddocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · Lot acquired 2022-09-01180 units · basis recordeddocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2024 · Value at 1 January 202441,200.00 CHFdocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2024 · Value at 31 December 202448,600.00 CHFdocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2024 · Value at 1 January, in USD46,800.00 USDdocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2024 · Value at 31 December, in USD55,200.00 USDdocument · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2024 · Exchange rate used (CHF per USD)0.881 as at 2024-12-31staff
  • Vanguard FTSE All-World UCITS ETF · 2024 · Distribution on 2024-06-26412.00 CHF (468.00 USD)document · swissquote-2024-statement.pdf
  • Vanguard FTSE All-World UCITS ETF · 2025 · Value at 1 January 202548,600.00 CHFstaff
  • Vanguard FTSE All-World UCITS ETF · 2025 · Value at 1 January, in USD55,200.00 USDstaff
  • Swisscanto (CH) Index Equity Fund World · 2024 · Value at 31 December 202422,300.00 CHFdocument · swissquote-2024-statement.pdf
  • Swisscanto (CH) Index Equity Fund World · 2024 · Value at 31 December, in USD25,300.00 USDdocument · swissquote-2024-statement.pdf

Validation (27)

  • pfic-1291 · 2025 · none — PFIC §1291 excess distribution (2025): no independent professional validation attached.
  • pfic-screening · 2025 · none — PFIC screening (2025): no independent professional validation attached.
  • fbar-thresholds · 2025 · none — FBAR thresholds (2025): no independent professional validation attached.
  • form-8938-thresholds · 2025 · none — Form 8938 thresholds (2025): no independent professional validation attached.
  • form-1116 · 2025 · none — Form 1116 foreign tax credit (2025): no independent professional validation attached.
  • form-2555 · 2025 · none — Form 2555 FEIE (2025): no independent professional validation attached.
  • niit · 2025 · none — Net investment income tax (2025): no independent professional validation attached.
  • filing-diagnostic · 2025 · none — Filing obligations diagnostic (2025): no independent professional validation attached.
  • case-diagnostic · 2025 · none — Case scope diagnostic (2025): no independent professional validation attached.
  • pfic-1291 · 2024 · none — PFIC §1291 excess distribution (2024): no independent professional validation attached.
  • pfic-screening · 2024 · none — PFIC screening (2024): no independent professional validation attached.
  • fbar-thresholds · 2024 · none — FBAR thresholds (2024): no independent professional validation attached.
  • form-8938-thresholds · 2024 · none — Form 8938 thresholds (2024): no independent professional validation attached.
  • form-1116 · 2024 · none — Form 1116 foreign tax credit (2024): no independent professional validation attached.
  • form-2555 · 2024 · none — Form 2555 FEIE (2024): no independent professional validation attached.
  • niit · 2024 · none — Net investment income tax (2024): no independent professional validation attached.
  • filing-diagnostic · 2024 · none — Filing obligations diagnostic (2024): no independent professional validation attached.
  • case-diagnostic · 2024 · none — Case scope diagnostic (2024): no independent professional validation attached.
  • pfic-1291 · 2023 · none — PFIC §1291 excess distribution (2023): no independent professional validation attached.
  • pfic-screening · 2023 · none — PFIC screening (2023): no independent professional validation attached.
  • fbar-thresholds · 2023 · none — FBAR thresholds (2023): no independent professional validation attached.
  • form-8938-thresholds · 2023 · none — Form 8938 thresholds (2023): no independent professional validation attached.
  • form-1116 · 2023 · none — Form 1116 foreign tax credit (2023): no independent professional validation attached.
  • form-2555 · 2023 · none — Form 2555 FEIE (2023): no independent professional validation attached.
  • niit · 2023 · none — Net investment income tax (2023): no independent professional validation attached.
  • filing-diagnostic · 2023 · none — Filing obligations diagnostic (2023): no independent professional validation attached.
  • case-diagnostic · 2023 · none — Case scope diagnostic (2023): no independent professional validation attached.

5 · Output

What ships, and what it is not

Formats

  • · Versioned JSON — every section above as one document (atamatax_export_version 1.2)
  • · CSV tables — one file per section, for a spreadsheet or your own tooling
  • · The client's PDF package (the CPA Export) when they bought one

Sample export (JSON) · CSV tables · the case it comes from

Generated 2026-09-17 · case graph schema 1.1

Boundaries, stated in the file

  • · Preparation material composed from the client's case; not a filed return, not a tax determination, and not a substitute for the practitioner's own review.
  • · A screening status is a classification from the instrument's identity. Only a reviewer-verified determination establishes a PFIC conclusion, and only a reviewer-approved year record establishes a Form 8621 obligation.
  • · Threshold analyses use the maxima on record, converted at the rate recorded on each row; an account without a recorded maximum makes the year's aggregate a lower bound.
  • · Form 8938 figures count reported accounts only; a specified asset held outside a reported account is not included unless it appears among the holdings.
  • · Nothing commercial between Atamatax and the client is included.

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