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Is my fund or ETF a PFIC?
Result
Tell us what you hold
Pick the closest match on the left, or paste your ISINs below and we'll flag each one.
Educational estimate, not tax advice. Domicile is the fund's legal home, not the broker or exchange you used. Broker and provider policies change — confirm current terms with your provider before acting.
What this tool answers
One question, answered properly.
It answers
Whether one foreign fund or ETF is likely a PFIC that needs Form 8621, from its vehicle type, legal domicile or ISIN — and which fact to confirm next when the answer is not clean.
Answered elsewhere
The tax. Classification and calculation are separate steps, and a domicile is a screening fact rather than the statutory §1297 income and asset tests.
The rest of the PFIC cluster
Each of these answers a different question.
- Form 8621 calculatorCalculate the Form 8621 §1291 numbers.
- PFIC filing cost calculatorWhat will Form 8621 preparation cost.
- Form 8621 complexity estimatorHow complex is my Form 8621 filing.
- PFIC portfolio analyzerAnalyze a whole portfolio for PFIC exposure.
- Swiss PFIC checkerIs my Swiss holding or Pillar 3a a PFIC.
- Form 8621 softwareHow the options compare — hand-built worksheet, a firm, or self-serve preparation.
FAQ
Is my fund a PFIC?
- Is my ETF a PFIC?
- A US-domiciled ETF is not a PFIC. A non-US ETF — including the Irish and Luxembourg UCITS funds most European and Asian brokers offer — is a pooled foreign vehicle and almost always needs PFIC analysis, because it is the fund's legal domicile that matters, not the exchange it trades on or where you live.
- Does an ISIN prove a fund is a PFIC?
- No. The first two characters of an ISIN identify the issuing jurisdiction, which is a strong screening signal but not the statutory test. PFIC status turns on the §1297 income and asset tests, and the ISIN prefix is not always the fund's tax domicile.
- Is a UCITS fund always a PFIC?
- A UCITS fund is a non-US pooled investment vehicle, so in practice it will normally meet the PFIC income or asset test and require analysis. It is still an analysis rather than an automatic status, and the filing requirement then depends on your holding, the reporting triggers and the exceptions in the Form 8621 instructions.
- The checker says my fund is likely a PFIC. What does that cost me?
- That depends on what happened during the year, not on the classification. A fund held all year with no distribution is a reporting question; a fund you sold, or one that paid an excess distribution, brings the §1291 calculation. Use the Form 8621 calculator for the tax, and the PFIC filing cost calculator for the preparation cost.
Before you rely on this result
What would settle it, and what covers it
Documents or facts needed
- • The fund's legal name and ISIN
- • The KID or prospectus (domicile and legal form)
- • How long it was held and whether it paid distributions
Where this leads
PFIC Portfolio · $499 — prepares the Form 8621 a likely PFIC needs.
Also possible: CPA Export ($199). The cheapest route that covers your facts is the right one; a package never covers more than one tax year.
How to read a status
- Likely:
- The facts entered meet the published test; confirm the inputs before acting.
- Possible:
- Some facts point this way and others are missing; more information decides it.
- Needs review:
- These inputs leave it open; a person should look before filing.
- Not currently indicated:
- Nothing entered triggers it this year; a changed fact can change the answer.
- Outside supported scope:
- This item is routed to a professional for preparation.
Scope. A screening result computed from the facts entered; not a legal classification and not individualized tax advice. This is a computation on the answers you gave, not individualized tax advice.
Tool: /tools/pfic-check
What changes the result
This answer changes if…
Whether a fund is treated as a PFIC
- …the fund is held inside a pension or retirement arrangement the U.S. recognises for this purpose — a treaty-recognised pension can take the fund out of Form 8621 reporting for the years it stays inside.
- …the fund turns out to be U.S.-registered under a European-sounding name — a U.S.-registered fund is not a PFIC at all; the ISIN decides it.
- …the instrument is a note or a certificate rather than a fund — an exchange-traded note or a structured certificate is a debt claim on its issuer, analysed differently.
- …you hold shares of the fund manager rather than units of one of its funds — an operating company is not a pooled vehicle; the domicile alone never decides it.
- …a reviewer has verified the classification — a screen from the fund's identity becomes a determination only when a person checks the fund's own facts.
What a PFIC costs in a given year
- …you sold the holding, in full or in part, during the year — a disposition is an excess distribution over the whole holding period, with interest, not a capital gain.
- …the fund paid you a distribution that exceeds 125% of the prior three years' average — the excess is thrown back across the holding period and taxed at each year's top rate.
- …a qualified electing fund or mark-to-market election was made in a prior year — an election changes the regime for every later year until revoked; the §1291 default no longer applies.
- …the fund publishes a PFIC Annual Information Statement — a QEF election becomes available; without the statement it cannot be made or kept.
- …the purchase date or the cost is not what the statement assumed — the holding period and the basis drive both the allocation and the interest; a reconstructed date moves both.
- …the year-end value is not the one used — under mark-to-market the year's inclusion is the change in value; a different value is a different figure.
Each line names a fact that moves the result; what it moves to depends on the rest of your facts. Nothing here is a determination.
How Atamatax calculations are produced — the tests applied, statutory sources and review cadence — is documented in the methodology, and how the engine is validated in accuracy & review. Calculation fixes are recorded in the changelog.
Authorities cited
- IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
- 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
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.