PFIC Election Optimizer
Compare Default Excess Distribution, QEF, and Mark-to-Market regimes over your holding period to find the lowest tax outcome.
PFIC Details
Select Regime to Analyse
๐ Default Excess Distribution Method
No election required. Excess distributions allocated back over holding period at top ordinary rate + interest charges. Most punitive regime โ but no upfront election required.
๐ QEF โ Qualified Electing Fund
Elect annually. Include your share of PFIC ordinary income and net capital gain each year. Avoids the excess distribution rules. Requires annual PFIC statement from fund โ many foreign funds don't provide this.
๐ MTM โ Mark-to-Market Election
Annual election. Include unrealised appreciation as ordinary income each year. Eliminates deferred gain. Available only if PFIC stock is "marketable." Losses limited to prior MTM income inclusions.
Regime Comparison
- QEF requires annual PFIC Annual Information Statement โ most non-US funds don't provide this
- MTM elections are irrevocable unless IRS consent obtained
- Default regime interest charges compound annually โ devastating for long holds
- Consider switching to US-domiciled equivalents (Vanguard US, Fidelity US) to avoid PFIC entirely
Get Expert PFIC Guidance
PFIC elections are permanent and complex. Consult a US tax attorney before electing.
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