PFIC / Form 8621 Checker 2026-2030

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Tax Year and Shareholder

Tax Year (current year)

The year of the distribution, disposition or inclusion.

Shareholder

Treas. Reg. §1.1298-1(c)(1) exception for listed tax-exempt holders.

Filing a joint return?

Raises the $25,000 Form 8621 value exception to $50,000. Treas. Reg. §1.1298-1(c)(2)(iii).

How the PFIC stock is held

Treas. Reg. §1.1298-1(b)(1), (2).

Total value of all PFIC stock you own on the last day of the year ($)

All PFICs: QEFs, section 1291 funds and mark-to-market stock, excluding stock held through another US person or another PFIC. Treas. Reg. §1.1298-1(c)(2)(ii).

Regime that applies to this PFIC

Section 1291 applies unless a QEF or mark-to-market election is in effect. IRC §1291(d)(1).

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PFIC Status Tests • IRC §1297

Income test

Passive gross income for the year ($)

Income of a kind that is foreign personal holding company income under IRC §954(c), subject to the exceptions in §1297(b)(2) (active bank, qualifying insurance corporation, certain related-person payments, export trade income).

Total gross income for the year ($)

PFIC if passive income is 75 percent or more of gross income. IRC §1297(a)(1).

Asset test

Stock regularly traded on a qualifying exchange?

Publicly traded corporations measure assets by value. IRC §1297(e)(1)(A), (e)(3).

Is the entity a controlled foreign corporation (CFC)?

A CFC that is not publicly traded measures assets by adjusted basis. IRC §1297(e)(2)(A).

Has the entity elected the adjusted-basis method?

Available only if not publicly traded. IRC §1297(e)(2)(B).

Average passive assets for the year ($)

Assets that produce, or are held to produce, passive income. Use the average over the taxable year. IRC §1297(a)(2).

Average total assets for the year ($)

PFIC if the average percentage of passive assets is at least 50 percent.

Overlap and look-back rules

Are you a US shareholder of the entity while it is a CFC?

CFC overlap rule: not a PFIC as to you during the qualified portion of your holding period. IRC §1297(d).

Was the entity a PFIC (and not a QEF) at an earlier time in your holding period?

Once-a-PFIC rule: the stock stays PFIC stock unless a purging election is made. IRC §1298(b)(1).

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Section 1291: Distributions and Dispositions

Complete for the default regime. Holding period runs from the acquisition date to the date of the distribution or disposition. Losses on disposition are not taken into account (Form 8621 instructions, line 15f). Enter whole dollars in US dollars; convert foreign currency first.

Date you acquired the stock

Holding period under IRC §1223. IRC §1291(a)(3)(A).

First year the entity was a PFIC

Days before January 1 of this year are pre-PFIC days. Assumes a calendar-year entity. IRC §1291(a)(1)(B)(ii).

Interest rate (percent per year, compounded daily)

Section 6621 underpayment rate for individuals; 7 percent for the fourth quarter of 2026. Actual interest uses each quarter's rate; see the assumptions table.

Your marginal ordinary rate (percent)

Applied to amounts included as ordinary income in the current year (lines 15e nonexcess and 16b).

Distributions this year

Total distributions this year (line 15a) ($)

Date of the distribution

If several, use the weighted date or run each separately. Excess is apportioned among distributions (Form 8621 instructions).

Creditable foreign tax on the excess distribution ($)

Reduces each PFIC year's increase in tax, not below zero. Line 16d.

Distributions 1 year earlier ($)

Reduce by prior excess distributions not included in income under IRC §1291(a)(1)(B). Line 15b.

Distributions 2 years earlier ($)

Distributions 3 years earlier ($)

Disposition this year (gain is treated as an excess distribution)

Gain recognized on disposition (line 15f) ($)

Enter gain only. Stock is disposed of if sold, transferred or pledged. IRC §1291(a)(2).

Date of the disposition

Creditable foreign tax on the gain ($)

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QEF: Current-Year Inclusion • IRC §1293

Enter the amounts from the PFIC annual information statement. A QEF shareholder includes a pro rata share of ordinary earnings and net capital gain whether or not distributed. IRC §1293(a).

Pro rata share of ordinary earnings (line 6a) ($)

Portion included under §951 or excludable under §1293(g) (line 6b) ($)

Pro rata share of net capital gain (line 7a) ($)

Portion included under §951 or excludable under §1293(g) (line 7b) ($)

Your marginal ordinary rate (percent)

Applied to line 6c.

Your long-term capital gain rate (percent)

Your own rate; not verified by this tool. Net capital gain is reported as a long-term gain on Schedule D (Form 8621 instructions, line 7c).

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Mark-to-Market: Current-Year Inclusion • IRC §1296

The election requires marketable stock. IRC §1296(e). Gain is ordinary income; loss is an ordinary loss only to the extent of unreversed inclusions. IRC §1296(a), (c).

Fair market value at year-end (line 10a) ($)

Adjusted basis at year-end (line 10b) ($)

Unreversed inclusions (line 11) ($)

Prior inclusions less prior deductions. IRC §1296(d).

First mark-to-market year, with the stock held before the election and not a QEF for every PFIC year?

Then section 1291 applies to the first-year mark-to-market gain as if it were gain on disposition. IRC §1296(j)(1). Uses the acquisition date, first PFIC year and interest rate entered below, with December 31 of the tax year as the event date.

Date you acquired the stock (first-year case only)

First year the entity was a PFIC (first-year case only)

Your marginal ordinary rate (percent)

Interest rate (first-year case only, percent)

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Results

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Purging and Related Elections

If the entity is a PFIC that is not a QEF, the stock stays PFIC stock for the rest of your holding period even in years when the tests are not met (IRC §1298(b)(1)). Elections on Form 8621 Part II can address this: a deemed sale election (IRC §1291(d)(2)(A); Treas. Reg. §1.1291-10), a deemed dividend election for a CFC (IRC §1291(d)(2)(B)), and the elections for former PFICs and section 1297(e) PFICs (Form 8621, Part II, Elections F, G and H). A QEF election is made on or before the due date, with extensions, of the return for the first year it is to apply (IRC §1295(b)(2)); a retroactive election is available only to the extent the regulations allow where the shareholder reasonably believed the company was not a PFIC. Each of these has conditions and consequences that this tool does not model.

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Assumptions and Sources

Assumptions & sources

Parameter	Value (selected year)	Status	Citation

Projected years and simplifications. The PFIC thresholds, the 125 percent rule and the highest-rate table for 2027 through 2030 are statutory and unchanged. The IRS has not published the Form 8621 or its instructions for those years, so line references follow the 12/2025 revision, and the interest rate is a user input because future quarterly rates are not known. Interest is estimated with one flat rate compounded daily; actual interest applies each quarter's rate under IRC §6621 (see Rev. Rul. 2024-18 and successor rulings for history). Net investment income tax, state tax, foreign currency translation, partial-year annualization of distributions (Prop. Treas. Reg. §1.1291-2) and multiple distributions on different dates are not modeled. Not tax advice.

Last verified: October 29, 2026

Authority: IRC §1(j) (as amended by Pub. L. 119-21, §70101); IRC §§1291, 1293, 1295, 1296, 1297, 1298; Treas. Reg. §1.1298-1; Treas. Reg. §1.1291-10; IRS Form 8621 (Rev. 12-2025) and Instructions for Form 8621 (12/2025); IRS news release IR-2026-98 (fourth quarter 2026 interest rates).

PFIC / Form 8621 Checker 2026-2030

How to use this checker

Tax Year and Shareholder

PFIC Status Tests • IRC §1297

Section 1291: Distributions and Dispositions

QEF: Current-Year Inclusion • IRC §1293

Mark-to-Market: Current-Year Inclusion • IRC §1296

Results

Purging and Related Elections

Assumptions and Sources