PFIC Annual Information Statement

A PFIC Annual Information Statement is a statement provided by a passive foreign investment company to a U.S. shareholder who has made, or wants to make, a Qualified Electing Fund election. For U.S. expats, it provides the information needed to report QEF income on Form 8621.

Why it matters for U.S. expats

A PFIC Annual Information Statement can make the difference between being able to use the QEF election and being stuck with the default PFIC excess distribution rules. Many foreign mutual funds, ETFs, investment trusts, and pooled investment products do not issue the statement, which means U.S. expats may have limited tax elections available even when the investment is ordinary or tax-favored in the country where they live.

Common questions

1. What is a PFIC Annual Information Statement used for?

It is used to support a QEF election and to report the shareholder’s share of the PFIC’s ordinary earnings and net capital gain on Form 8621.

2. Who provides a PFIC Annual Information Statement?

The PFIC provides the statement to its U.S. shareholders. If the shareholder holds the PFIC through an intermediary, an Annual Intermediary Statement may be provided instead.

3. What information must the statement include?

The statement must include the shareholder’s pro rata share of the PFIC’s ordinary earnings and net capital gain for the year, or enough information for the shareholder to calculate those amounts.

4. Is a PFIC Annual Information Statement the same as Form 8621?

No. Form 8621 is the IRS form the U.S. shareholder files. The PFIC Annual Information Statement is supporting information from the PFIC or intermediary.

5. Is the statement required for a QEF election?

Yes. A U.S. shareholder needs the PFIC Annual Information Statement, Annual Intermediary Statement, or acceptable supporting documentation to make and maintain a QEF election.

6. What is a QEF election?

A QEF election treats the PFIC as a Qualified Electing Fund. The shareholder reports their share of the PFIC’s ordinary earnings and net capital gain each year, rather than waiting until distributions or sale.

7. Does QEF income have to be reported even if nothing is distributed?

Yes. Under the QEF rules, the shareholder reports their pro rata share of ordinary earnings and net capital gain even if the PFIC does not pay out cash.

8. Does every foreign fund provide a PFIC Annual Information Statement?

No. Many foreign mutual funds, ETFs, and investment platforms do not provide the statement in the format needed for U.S. PFIC reporting.

9. What happens if the PFIC does not provide the statement?

The shareholder may be unable to make or maintain a QEF election. The investment may instead fall under the default section 1291 rules or, if available, the mark-to-market election.

10. Can an Annual Intermediary Statement replace the PFIC Annual Information Statement?

Yes. If the PFIC is held through an intermediary, an Annual Intermediary Statement can be used when it contains the required information.

11. Can one statement cover multiple PFICs?

It can. A combined statement may be available when a PFIC owns lower-tier PFICs or when an intermediary holds multiple PFICs for the shareholder.

12. Should the statement be attached to the tax return?

The shareholder uses the information to complete Form 8621. They should keep the statement, Form 8621, and related attachments because the IRS can request them.

13. What happens if the shareholder cannot produce the statement later?

Failure to produce the required Form 8621 attachments, PFIC Annual Information Statements, or Annual Intermediary Statements can result in the QEF election being invalidated or terminated.

14. What records should U.S. expats keep with a PFIC Annual Information Statement?

Keep the statement, Form 8621, purchase records, sale records, distribution records, account statements, exchange-rate calculations, prior-year PFIC forms, QEF election records, and any correspondence from the fund or intermediary.

When to get help

Professional guidance is important when:

  • You own foreign mutual funds, foreign ETFs, investment trusts, or other pooled foreign investments.
  • You received a PFIC Annual Information Statement or Annual Intermediary Statement.
  • You want to make a QEF election.
  • You previously filed Form 8621 without a QEF election and want to review your options.
  • Your fund does not provide the statement.
  • You own PFICs through a foreign pension, foreign trust, foreign company, or investment platform.
  • You need to compare QEF, mark-to-market, and section 1291 treatment.
  • You have missed prior-year PFIC reporting.

Bright!Tax can review PFIC holdings, determine whether a QEF election is available, prepare Form 8621, and coordinate PFIC reporting with FBAR, FATCA, and the rest of your U.S. expat tax return. Get started with Bright!Tax.

Official sources

Reviewed by

Katelynn Minott, CPA & CEO

Last reviewed

July 2026

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