Broker · Canada
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
Updated September 2026
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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 holds | US-listed alternative (not a PFIC) |
|---|---|---|
| VFV — Vanguard S&P 500 Index ETF | The S&P 500, via a Canadian wrapper | VOO, IVV, SPY |
| ZSP — BMO S&P 500 Index ETF | The S&P 500, via a Canadian wrapper | VOO, IVV, SPY |
| XIC — iShares Core S&P/TSX Capped Composite | Broad Canadian equities | EWC (a US-domiciled iShares fund on a different Canadian index) |
| XEQT / VEQT — all-in-one equity portfolios | A basket of Canadian, US and international ETFs | No single US-listed equivalent — a mix of US-listed funds |
| Any Canadian mutual fund | Whatever its mandate says | — |
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 account | US treatment | Read |
|---|---|---|
| RRSP, RRIF, LIRA, spousal RRSP | Treaty deferral; FBAR / 8938 reporting | RRSPs and US tax |
| TFSA | No deferral; income taxed annually; trust question open; PFICs inside | TFSAs and US tax |
| FHSA | No deduction, no deferral; trust question open; PFICs inside | FHSAs and US tax |
| RESP | No deferral; grant taxable; trust question; PFICs inside | RESPs and US tax |
| Margin / cash | Taxed as it arises; PFICs inside | Canadian 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
- In Questrade's reports, export the positions table for each account as CSV — one per account, so the wrapper stays attached to its holdings.
- Export the account activity for the year as CSV. It carries every buy, sell, dividend and distribution with the date and the currency.
- 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.
- 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.
- Pull the T3 and T5008 slips: distributions by fund and every sale with proceeds and cost, which is what a §1291 computation needs.
- 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 review signals, not a determination.
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.