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7 Comments

  1. @shany, we will be kicking up a new mailing list for regular updates and info on PFICs. It will be available for signup on hodgen.com/lists on May 1, 2015.

  2. What happens in my case?
    I’m a US person who bought Central Fund of Canada ( Amex CEF A ) shares in 2009 in a taxable US brokerasge account.CEF is a PFIC closed end mutual fund which hold physical gold and silver, and doesn’t pay ordinary earnings or net capital gains,dividends are nil ( $0.01).I did not sell any stocks in 2009 or 2010.These shares went up in both years.

    No actual income to report.
    I omitted these shares in F1040 and schedules B & D and TD F90-22.1 timely filed.
    The questions are :
    1) should I file F8621 ? for both years?
    2)If I didin’t get any distribution or gain, can I enter Part III lines 5-6-7 and ignore Part IV ?

    “A tax liability under the excess distribution rules arise only when an actual distribution is made by the PFIC, or when the US investor disposes of his investment in the PFIC”

    Your help would be greatly appreciated.

  3. The real fun starts when (as is almost always the case) the PFIC was purchased many years prior to sale.

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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.