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Questrade for US citizens: one account, PFICs and non-PFICs side by side

Questrade gives a US citizen in Canada access to both the TSX and the US exchanges — which is exactly why it is the broker where a portfolio most often ends up half PFIC and half not. The listing decides, not the broker.

By Danilson Ramos · Founder, Atamatax

Published September 2026 · Updated October 2026

Your situation, in five answers

What happened
You are a US citizen in Canada with a Questrade account that holds TSX-listed ETFs or Canadian mutual funds — possibly next to US-listed ones in the same account.
Why it matters
The listing decides, not the broker: a US-listed ETF bought at Questrade is not a PFIC; a TSX-listed ETF or Canadian fund commonly is. The same index can sit a click apart with opposite US answers.
What it could trigger
Each Canadian-listed fund may be a PFIC with its own Form 8621 per year; a TFSA, FHSA or RESP holding it adds a wrapper question; the account itself may need the FBAR and Form 8938.
What you need
Questrade's positions or activity export as CSV — ticker per holding, purchase dates and cost per lot, distributions — plus which account type each position sits in and the account's maximum value in the year.

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

Free tool · no account · nothing saved

Check your Questrade holdings

Export your positions or activity as CSV, or add each fund by ticker. Every holding is screened for PFIC status — the TSX-listed ones and the US-listed ones come back with different answers.

Questrade's pitch is choice: every TSX listing and every US listing in one self-directed account, at low cost. For a US citizen in Canada that choice is the whole tax question. Two ETFs tracking the same index sit a click apart in the same order ticket, and one of them commonly needs a Form 8621 every year while the other never will.

Where the exposure comes from: the listing, not the broker

A PFIC is a non-US pooled investment vehicle. A TSX-listed ETF is organised as a Canadian mutual fund trust — non-US, pooled — and is commonly treated as a corporation for §1297 purposes. A US-listed ETF is a US registered investment company and cannot be a PFIC, whoever the broker is and whichever country you sit in. Questrade lets you hold both, so the question for every line on your statement is which exchange it trades on.

TSX-listed (commonly a PFIC)What it holdsUS-listed alternative (not a PFIC)
VFV — Vanguard S&P 500 Index ETFThe S&P 500, via a Canadian wrapperVOO, IVV, SPY
ZSP — BMO S&P 500 Index ETFThe S&P 500, via a Canadian wrapperVOO, IVV, SPY
XIC — iShares Core S&P/TSX Capped CompositeBroad Canadian equitiesEWC (a US-domiciled iShares fund on a different Canadian index)
XEQT / VEQT — all-in-one equity portfoliosA basket of Canadian, US and international ETFsNo single US-listed equivalent — a mix of US-listed funds
Any Canadian mutual fundWhatever its mandate says—
Same index, different entity. VFV and VOO both track the S&P 500 and both are Vanguard. VFV is a Canadian trust that holds the US fund; VOO is the US fund. Only one of them is foreign to the IRS.

Each of those tickers has its own page with the fund-level detail: VFV, ZSP, XIC, XEQT, VEQT, and the balanced and growth portfolios XGRO and VGRO.

Norbert's gambit and the currency ETF

Questrade users convert Canadian dollars to US dollars cheaply by buying a TSX-listed US-dollar currency ETF in CAD, journaling it to the USD side and selling it there — Norbert's gambit. The instrument in the middle is a Canadian ETF, which is to say a Canadian mutual fund trust holding US-dollar cash. For a US person it is screened like any other non-US pooled vehicle: commonly a PFIC, bought and then sold.

The gain on the round trip is usually tiny — a few dollars of exchange-rate movement — but a sale of PFIC stock is a disposition under §1291, and whether the annual-reporting exception for small PFIC holdings applies depends on the year's numbers rather than on the holding being brief. Do not assume it away; put the gambit legs into the scan like any other sale.

Registered accounts at Questrade

Questrade offers every registered wrapper, and the wrapper decides the US analysis more than anything on this page. Under Article XVIII of the 1980 Convention, automatic since Rev. Proc. 2014-55, an RRSP, RRIF or LIRA defers US tax on the income inside and its funds generate no annual PFIC consequences while the deferral holds. A TFSA, an FHSA or an RESP defers nothing for US purposes: the income is taxed as it arises, the Canadian-listed funds inside are analysed as PFICs each year, and the wrapper raises an open Form 3520 question. A margin or cash account is simply taxable, as anywhere.

Questrade accountUS treatmentRead
RRSP, RRIF, LIRA, spousal RRSPTreaty deferral; FBAR / 8938 reportingRRSPs and US tax
TFSANo deferral; income taxed annually; trust question open; PFICs insideTFSAs and US tax
FHSANo deduction, no deferral; trust question open; PFICs insideFHSAs and US tax
RESPNo deferral; grant taxable; trust question; PFICs insideRESPs and US tax
Margin / cashTaxed as it arises; PFICs insideCanadian funds and the PFIC rules

Questwealth portfolios

Questrade's managed service builds a portfolio from ETFs and rebalances it. For US purposes the portfolio is not one thing: each Canadian-listed ETF inside it is screened on its own and commonly a PFIC, each US-listed ETF is not, and the account type applies to all of them. The holdings breakdown for the year you are filing is the document to start from.

Exporting your Questrade data

  1. In Questrade's reports, export the positions table for each account as CSV — one per account, so the wrapper stays attached to its holdings.
  2. Export the account activity for the year as CSV. It carries every buy, sell, dividend and distribution with the date and the currency.
  3. Note the currency of each figure. Questrade accounts run a CAD side and a USD side; the scanner leaves non-USD amounts blank rather than converting them with a rate it invented, and the IRS yearly-average rate is the usual choice for the conversion.
  4. For each holding, record the exchange it trades on. TSX means Canadian, NYSE or Nasdaq means US — the single fact that decides the PFIC question.
  5. Pull the T3 and T5008 slips: distributions by fund and every sale with proceeds and cost, which is what a §1291 computation needs.
  6. Run the scanner below on each account's export. It screens every holding, counts the potential Forms 8621, and names the FBAR, Form 8938 and catch-up questions the account raises.

Elections, briefly

Canadian ETF issuers do not generally publish the PFIC Annual Information Statement a QEF election requires, so for a TSX-listed fund the realistic choice is between the default §1291 regime and a mark-to-market election under §1296. Mark-to-market is often the one to check first because these funds are exchange-traded, though whether a specific listing qualifies as marketable stock on a qualified exchange must be confirmed. The cleanest answer of all, for a non-registered account, is the one Questrade makes available: hold the US-listed fund instead, and the question never arises.

Find out which of your Questrade holdings are PFICs

Export your positions or add each fund by ticker, and the free scanner screens every one — TSX-listed and US-listed alike. Domicile and instrument type are the review signals; the fund's own annual facts settle it.

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
  • IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • 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
  • US–Canada Income Tax Treaty — Convention between the United States and Canada (signed 1980), as amended by its five Protocols
  • Rev. Proc. 2014-55 — Rev. Proc. 2014-55 — automatic tax deferral for Canadian RRSPs and RRIFs; eliminates the Form 8891 election
  • FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
  • IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets

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

Can a US citizen open a Questrade account?#
Yes, as a Canadian resident. Questrade collects a W-9 and the FATCA information a US person's account requires. The account is not the issue; what is inside it, and which account type it is, are the US questions.
Is VFV a PFIC? What about VOO in the same account?#
VFV, the TSX-listed Vanguard S&P 500 Index ETF, is a Canadian mutual fund trust — a non-US pooled vehicle commonly treated as a PFIC, with its own Form 8621 each year outside an RRSP. VOO, the NYSE Arca-listed Vanguard S&P 500 ETF, is a US fund and is not a PFIC. Same index, same sponsor, different entity — and Questrade lets you hold either.
I did Norbert's gambit at Questrade. Do I have a PFIC?#
The currency ETF in the middle of the gambit is a TSX-listed Canadian mutual fund trust, so for a US person it screens as a PFIC that was bought and sold. The gain is usually a few dollars, but a sale of PFIC stock is a §1291 disposition, and whether the small-holding reporting exception applies turns on the year's figures rather than on how briefly you held it. Put the legs into the scan.
Is my Questrade TFSA a problem?#
Not the account itself — the treatment. The income inside is taxable on Form 1040 in the year it arises because the exemption is Canadian only; the Canadian-listed funds inside are analysed as PFICs each year; the account counts toward the $10,000 FBAR aggregate and Form 8938; and whether the wrapper is a foreign trust for Form 3520 purposes is an open question.
Does Questrade issue a Form 1099?#
No. Questrade reports to the CRA and issues Canadian slips — T3 for fund distributions, T5 for interest, T5008 for sales — plus the activity and positions exports. A US return is built from the underlying facts those carry: each fund's distributions, each sale's proceeds and cost, year-end values, and the exchange each holding trades on.
Which Questrade export should I use for the scanner?#
The positions export for what you still hold at year end, and the account activity export for what you sold during the year. Export one per account so the wrapper stays attached, and expect non-USD amounts to come through blank — the scanner will not invent an exchange rate.

Related guides

Preparation · price before you start

If you want the Forms 8621 prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

  1. Your returns are up to date and the non-US funds are the complication

    PFIC Portfolio · $499 · Self-serve preparation

    PFIC Portfolio covers portfolios of four to twenty-five likely PFICs, with a Form 8621 drafted per fund.

    What arrives, who prepares and checks it, and who files

    Everything in Simple plus up to 25 supported Forms 8621 — line-mapped worksheets until independent validation of the official PDFs completes — with QEF / mark-to-market / §1291 inputs per holding, fund-domicile classification with confidence shown, and the assumption log — for one tax year.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Prepare my PFIC portfolio
  2. You already work with an accountant who files for you

    CPA Export · $199 · Accountant handoff

    You already have an accountant. CPA Export gives them the per-fund PFIC screen with its reasons and the threshold arithmetic, so the fund question is settled before the return is drafted.

    What arrives, who prepares and checks it, and who files

    A PDF hand-off for an accountant: the holdings and PFIC classification table, the potential Form 8621 workload, FBAR/Form 8938 threshold logic, worksheets mapped to form lines, and the assumption log — for one tax year.

    The engine builds the PFIC analysis and the worksheets from the entries you confirm. Your accountant prepares the return from them.

    Nobody at Atamatax reviews the export before you download it. Your accountant checks it — every classification and figure carries the assumption behind it.

    Your accountant files the return, or you do; the FBAR is filed on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Build my CPA Export
  3. Returns, FBARs or Forms 8621 are missing for earlier years

    Streamlined Investor · $2,200 · Scoped by hand

    The catch-up years include non-US funds or a personal foreign plan, so each back year needs PFIC work as well as the return and the FBAR.

    What arrives, who prepares and checks it, and who files

    A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official pre-filled PDFs only for tax year 2025), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.

    A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.

    A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote
  4. More than twenty-five funds, or the fund facts are incomplete

    Confirm the scope before choosing a package · Free to ask

    More than twenty-five likely PFICs is past the included limit of every package; the scope is confirmed by hand before a price is named.

    What arrives, who prepares and checks it, and who files

    Free to ask. A person reads the facts and says whether Atamatax can take the case, and which route it would be.

    A person at Atamatax reads the facts before any route is offered.

    See whether Atamatax can take the case

When a professional's judgment is needed. Checkout stops and sends you to a person when there are more than twenty-five likely PFICs. Whether a late QEF or mark-to-market election can still be made turns on the facts and is a professional's call, which the package does not make — if that is your question, ask before you buy.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com reach a person — we aim to reply within one business day. Who does what in each route.

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.

Your next step · free

Which of your holdings are PFICs — and how many forms?

Import the positions export or add each holding, and every position is screened for PFIC status with the forms it implies — the same engine a paid return uses. Free, no account.