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Saxo Bank & PFICs for US expats

Saxo's European platform sells UCITS funds — PFICs for a US taxpayer — and the account itself triggers FBAR and Form 8938 checks.

By Danilson Ramos · Founder, Atamatax

Published July 2026 · Updated September 2026

Your situation, in five answers

What happened
You hold a Saxo account as a US person living in Europe — often a legacy one opened before Saxo's US-person policy tightened — and it contains funds or ETFs.
Why it matters
Saxo's ETF shelf is UCITS, so the funds it sells are the ones US tax treats worst. Individual shares and bonds in the same account are fine; the pooled funds are the question.
What it could trigger
Each UCITS ETF or European fund may be a PFIC with its own Form 8621 every year under the §1291 default. The account itself may need the FBAR and Form 8938 whatever it holds.
What you need
Saxo's annual statement with an ISIN and year-end value per position, the account's maximum value in the year, and — for any fund sold or paying a large distribution — the purchase dates and cost of each lot.

Part of the Denmark desk — every US tax topic for Denmark 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.

Saxo Bank is a common platform for professionals across Europe. For a US person it raises the standard two questions: are the funds PFICs, and what does the account itself trigger?

Can a US person use Saxo Bank?

Saxo generally does not serve US residents, and its treatment of US citizens resident in Europe varies by entity and has tightened over time (per Saxo's published terms and consistent user reports — confirm with Saxo for your country). Many US persons hold legacy accounts opened before a policy change.

The PFIC question

Like every EU retail platform, Saxo's ETF shelf is UCITS (PRIIPs rules keep US-domiciled ETFs off it). UCITS ETFs and European mutual funds are generally PFICs for a US taxpayer — one Form 8621 per fund per year, with the §1291 default regime unless you elect QEF or mark-to-market.

Holding at SaxoPFIC?Typical filing
UCITS ETF (ISIN IE, LU…)LikelyForm 8621 each year
European mutual fundLikelyForm 8621 each year
Individual shares / bondsNoReport the account
Cash (multi-currency)NoFBAR / Form 8938 if over threshold

FBAR and Form 8938

A Saxo account is a foreign financial account for both tests: it counts toward the $10,000 FBAR aggregate (maximum value during the year) and the Form 8938 thresholds (year-end and maximum). Saxo's annual statement carries the values you need.

  • Export the portfolio / annual statement with ISINs and year-end values.
  • Use each ISIN prefix to identify the issuer jurisdiction, then confirm the legal vehicle and annual §1297 facts; the exchange itself does not decide PFIC status.
  • Record the account's maximum value during the year for the FBAR.

How many forms, and when this stops being a DIY return

Form 8621 is filed per PFIC, per year, so the size of the job is the number of funds multiplied by the years you held them. A fund sold in the year, or one that paid a large distribution, adds the §1291 allocation — the gain spread across every day of the holding period, taxed at each year's top rate with interest — which needs the purchase date and cost of each lot, not just the year-end statement. Atamatax's PFIC package prepares up to 25 Forms 8621 inside one return for a flat $499. It stops being a self-serve return when earlier years were never filed (a catch-up question first), when lots bought years ago have no cost basis, or when an election has to be chosen consistently across many funds — those are scoped as a case before anything is bought.

What Atamatax can evaluate

Free: screen each ISIN for PFIC indicators, run the whole statement through the portfolio analyzer, and estimate the number of Forms 8621. Paid: prepare those forms inside the return, arithmetic shown. Not from software: a legal determination on a specific fund, any view on willfulness, or Saxo's policy on your account — the fund's annual facts, a legal question and the bank's terms respectively.

Check your Saxo holdings before you file

Paste your ISINs — the free checker screens each holding for PFIC indicators and names the next record to confirm; the analyzer takes the whole statement. This is general information, not individualised tax advice.

Broker policies change — confirm current Saxo terms with Saxo. Atamatax provides preparation software and educational estimates, not individualised tax, legal, or investment advice.

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 §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • 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
  • 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
  • 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

Does Saxo accept US citizens living in Europe?#
US residents are generally not served, and treatment of US citizens in Europe varies by Saxo entity and has tightened over time. If you hold a legacy account, the PFIC and FBAR analysis applies regardless. Confirm with Saxo for your country of residence.
Are Saxo's ETFs PFICs for me?#
Yes — the ETFs on Saxo's European shelf are UCITS funds, which are generally PFICs for a US taxpayer. Individual stocks and bonds are not. Check each ISIN — the checker does this in bulk.
What Saxo data do I need for my US filing?#
Saxo's annual statement: every position with ISIN and year-end value, plus the account's maximum value during the year (FBAR uses the maximum; Form 8938 uses both). For any fund sold or paying a large distribution, add the purchase date and cost of each lot — the §1291 computation cannot be done without them.
How many Forms 8621 will my Saxo account need?#
One per PFIC per year: the UCITS funds you held, times the years you held them. Atamatax's PFIC package covers up to 25 in one return; a larger portfolio, or one with unfiled prior years, is scoped as a case first.

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 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 PDFs for the current filing year), 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. A person reads the facts before any package is sold when the fund screen cannot finish, when there are more than twenty-five likely PFICs, or when a late QEF or mark-to-market election is in question — whether a late election can still be made turns on the facts and is a professional's call.

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 get a 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.

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