How Passive Foreign Investment Corporation (PFIC) Tax Rules Affect most Americans Abroad

Our paper outlines major takeaways for U.S. taxpayers who have invested in a Passive Foreign Investment Corporation (PFIC), namely:

  • Tax treatment of PFICs is highly punitive compared to U.S.-domiciled funds. It explains the filing requirements for shareholders and details three tax elections for reporting PFIC information, including:

  1. The Qualified Electing Fund (QEF) Election

  2. The Mark-to-Market Election

  3. The Default, or “Do Nothing,” Approach

  • Beyond high tax rates, the stringent tax reporting requirements surrounding PFICs make it time-consuming and expensive to properly comply.

  • One of the most effective ways to mitigate the negative financial consequences of PFIC ownership is to invest using individual securities.


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