If you're a U.S. person holding foreign mutual funds, pension accounts, or investment products abroad, you almost certainly have PFIC exposure. These jurisdiction-specific guides identify which accounts create Form 8621 filing obligations — and what to do about them.
Technical deep-dives into local fund structures, pension schemes, and Form 8621 reporting requirements for U.S. persons abroad.
KiwiSaver is a mandatory workplace retirement scheme where sub-fund investments almost universally qualify as PFICs. For U.S. persons living in NZ, both employer and employee contributions create Form 8621 obligations — with no treaty exemption.
Read Guide →The U.S.-Australia tax treaty does not protect superannuation from PFIC rules. Managed funds held within industry funds, retail funds, or SMSFs are likely PFICs requiring Form 8621.
Read Guide →RRSP is treaty-protected. TFSA and RESP are not. Canadian mutual funds and TSX ETFs are PFICs — and some (Manulife, Vanguard) issue AIS data enabling QEF elections.
Read Guide →ISAs provide no US tax protection. OEICs and UK-based investment trusts are standard PFICs. For U.S. persons in the UK, understanding the interaction with the UK-US treaty is essential for Form 8621 compliance.
Read Guide →Every country guide uses a consistent three-level risk framework based on the likelihood that typical local investment products qualify as PFICs, treaty protection availability, and the practical complexity of filing Form 8621 for that jurisdiction.
Most local investment funds and pension sub-funds qualify as PFICs. No meaningful treaty protection for the most common accounts. Mandatory employer schemes create unavoidable exposure. U.S. persons in these jurisdictions almost certainly need to file Form 8621.
PFIC exposure exists but treaty provisions reduce or eliminate it for some account types. Employer pension contributions may be protected while personal investment funds remain exposed. Filing obligation depends on which specific accounts you hold.
Strong treaty provisions protect the most common local investment structures. Remaining PFIC exposure is typically limited to directly-held foreign funds outside treaty-protected accounts. Filing may not be required if only treaty-protected accounts are held.