Budget-friendly Form 8621 — PFIC

Form 8621 — who files it, when it is due, what late filing costs, and what we charge to prepare it. United States (IRS). Budget-friendly Form 8621 with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

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  • 15+ years of cross-border experience
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In 60 words

Form 8621 is an election: Reports and elects the treatment of a passive foreign investment company — most commonly a non-US mutual fund or pooled investment. US persons holding shares in a foreign pooled investment, including anyone who bought ordinary index funds or mutual funds in the country they moved to.

Do you need this?

US persons holding shares in a foreign pooled investment, including anyone who bought ordinary index funds or mutual funds in the country they moved to.

The question below is the one that actually determines the outcome. The default regime is designed to be worse than the alternatives: without a timely election, distributions and gains are thrown back across the holding period with an interest charge. The whole planning question is which election to make, and when.

The firm’s founder at his desk in the Delhi office

Fixed fees for form 8621 PFIC, agreed up front

The fee on a PFIC filing is decided by how many foreign funds you hold and how many years they have gone unreported. Each fund is its own computation, and one that has sat undeclared across several holding years is a different engagement from a single fund bought this year. Quoted in writing first.

FBAR & Form 8938 disclosure — fixed-fee price

From $449

fixed, quoted before work starts

Both US foreign-asset reports prepared from one account and asset list, with the different contents each of them requires, and reconciled to the return they accompany.
See the full fee page

Streamlined catch-up — 3 years + 6 FBARs — fixed-fee price

From $449

fixed, quoted before work starts

The full streamlined submission: the back returns, the account reports for the whole period, and the non-willfulness certification that is the substance of the application.
See the full fee page

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Disclosure of assets and interests held abroad, built once from a single asset list and filed on every side that asks for it.
See the fee schedule

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

For a filing history that stopped — the penalty position assessed first, then the years filed in the order that protects it.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Company filings where income, ownership or operations cross a border, with the related-party disclosures that come with them.
See the fee schedule

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.
See the fee schedule

All published fees on one page — all of it on a single page, so the number you compare is the number you pay.

What the reporting test actually looks at

What decides whether Form 8621 applies
The choice being madeWhat it changes
The obligationReports and elects the treatment of a passive foreign investment company — most commonly a non-US mutual fund or pooled investment.
Who it bindsUS persons holding shares in a foreign pooled investment, including anyone who bought ordinary index funds or mutual funds in the country they moved to.
Jurisdiction and authorityUnited States — IRS
Category of filingElection

When it is due

Elections run on their own clock, and it is usually tied to the transaction or the return for the year of the event rather than to a general filing date. A late election may be accepted in defined circumstances, and it may not — which makes the date the single most important fact about this form. Where an extension is available we tell you what it does and does not cover, because the two are frequently confused.

What late or missed filing costs

The consequence of a missed election is the default treatment, and the defaults in this area are deliberately unfavourable. There is often no penalty at all — just a materially worse tax outcome that cannot be reversed once the window has closed. Where years are already missed, the route chosen for the earliest year affects the relief available for the rest — so the sequence is decided before anything is filed.

The numbers, end to end

The same point, with figures rather than adjectives.

Gross withholding against a net-basis return

A non-resident receives C$21,000 in the year. Assume withholding at 28% on the gross amount, and assume deductible costs of C$15,120 against it.

Gross withholding against a net-basis return
ItemAmount
Gross amount receivedC$21,000
Withheld at source (assumed 28% of gross)C$5,880
Deductible costsC$15,120
Net amount actually earnedC$5,880
Tax on the net amount (assumed graduated result)C$1,940
Difference recoverable by filingC$3,940

Filing on a net basis recovers C$3,940 of the C$5,880 withheld. That difference is the entire reason the elective return exists, and it is lost by not filing. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

The figures here are an illustration, not an engagement: amounts are picked so the mechanism is easy to follow, and every rate or threshold is an assumption of the example. Before anything is filed for you, each one is confirmed with the issuing authority for your own tax year.

How we prepare and file it, and what it costs

Form 8621 is priced as part of the filing set it travels with, quoted in writing before any work begins. A change in scope is re-quoted rather than added to the invoice. See the how to avoid double taxation for comparable engagements.

The four steps

  1. 1Model the outcome with and without the election before filing anything
  2. 2Confirm the deadline and whether a late election route exists
  3. 3Prepare the election with the valuations and computations it requires
  4. 4File it, and record the elected amounts for every future year that depends on them
  • Every statutory figure in your file is verified for your own year at source.
  • Authorisation with each authority, so we see the assessments and slips directly rather than asking you for them.
  • Nothing is filed until you have read it.

If a letter prompted this, bring the letter — it usually contains the answer to half the questions.

Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

IRS form 8621, in practice

Most readers of this page are looking for IRS form 8621. What follows sets out how it works for Form 8621: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

The default regime is designed to be worse than the alternatives: without a timely election, distributions and gains are thrown back across the holding period with an interest charge.

From first contact to filed return

  1. Tell us the dates and we will tell you the position

    Arrival, departure, the years in between — the residence question turns on those before anything else.

  2. Fixed fee, defined scope, in writing

    Both agreed before work starts, so the engagement cannot grow into a larger bill.

  3. Prepared together, not passed between firms

    You are not the go-between for two sets of advisers working from two sets of assumptions.

  4. Reviewed, approved, filed

    A named practitioner checks it, you approve it, and then it goes.

How form 8621 PFIC is handled here

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

The vocabulary this page leans on

Streamlined domestic offshore
The US catch-up route for non-willful filers resident in the United States, which carries a penalty computed on the unreported asset values.
Credit method
A relief method under which the residence country taxes the foreign income and allows the foreign tax against its own, up to its own tax on that income.
MLI
The multilateral instrument, which modified many existing treaties at once. The treaty text in force is the modified text, together with each country's reservations.
Bona fide residence test
The other US qualifying test, satisfied by being a genuine resident of a foreign country for an uninterrupted period covering a full tax year.
form 8621 PFIC: Our analysis

The default regime is designed to be worse than the alternatives: without a timely election, distributions and gains are thrown back across the holding period with an interest charge.

None of what follows shifts the terms. Scope and fee are settled in writing before anything is prepared, the result carries a named reviewer, and nothing is filed unseen.

Form 8621 PFIC — what the published fees look like

The other thing that moves the price is which PFIC election is open to you. A mark-to-market position can often be run from ordinary year-end values, while a qualified electing fund route depends on the fund issuing an annual information statement. Where no statement exists, the computation falls back to the default regime and grows accordingly.

Catch-up & voluntary disclosure

$349fixed, before work starts

Covers: Voluntary disclosure handled as one piece of work, from the review of what is outstanding to the returns that close it.

See this fee page

Individual tax filing

$349fixed, before work starts

Covers: One engagement for a personal return that touches more than one country: the income, the assets held abroad and the relief claimed against them.

See this fee page

The difference a dedicated cross-border team makes

Filed with the authority, not just prepared

The engagement runs to submission and to the correspondence that follows it, including the queries that arrive months later.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

You deal with the person who did the work

The practitioner who prepared and reviewed your file is the one who answers the question about it.

The team reviewing a file together at a desk

From first call to filed return

Step 1

Establishing the facts

A call to our 24-hour helpline to establish the facts and the dates that matter

Step 2

Agreeing the fee

A written scope and a fixed fee before any work starts

Step 3

Drafting and review

Preparation, then a named reviewer's sign-off before anything is filed

Step 4

Filing and follow-up

Filing, then payment — after you have seen and approved the result

Two of the firm’s advisers and the team in the open-plan office

A fixed quote first, in writing

  • Step 1: Upload the file as it stands – A secure link arrives after the first call. Incomplete is fine; that is what the review is for.
  • Step 2: The number is settled up front – Priced from your own documents and confirmed in writing before any preparation begins.
  • Step 3: Both returns on one desk – One engagement covers every country the file touches, reconciled line against line.
  • Step 4: Your approval, then the filing – The return is yours to check first. We file once you say so.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

More of the same work, from other angles

Every link below is a full page of its own — the same depth as this one, for its own subject.

The work we do for clients like this

Form 8854 — expatriation statement, the US exit tax US exit tax — the guide, the FAQ and the fixed fee.
UK VAT registration The full guide to UK vat registration, with the fee fixed before any work starts.
Form 8288-A — FIRPTA statement Its own page: form 8288-a FIRPTA statement — mechanism, deadlines and published fees.
Indian company setting up in the US Everything on Indian company setting up in the US, at the same depth as this page.
Students and trainees — the treaty article Students trainees treaty article — the guide, the FAQ and the fixed fee.
Form T2062A — depreciable / resource property The full guide to t2062a depreciable resource property, with the fee fixed before any work starts.
Indian resident with foreign assets (Schedule FA) Its own page: Indian resident with foreign assets schedule fa — mechanism, deadlines and published fees.
Cost-sharing arrangements Everything on cost-sharing arrangements, at the same depth as this page.
OIDAR services in India OIDAR services in India — the guide, the FAQ and the fixed fee.

Clients who arrive with this exact page

Tax for offshore vessel crew Offshore vessel crew tax — the guide, the FAQ and the fixed fee.
Tax for twitch & live streamers The full guide to twitch & live streamers tax, with the fee fixed before any work starts.
Tax for models Its own page: models tax — mechanism, deadlines and published fees.
Management consultants — what you owe in each country Everything on management consultants what you owe in each country, at the same depth as this page.
Day traders — what you owe in each country Day traders what you owe in each country — the guide, the FAQ and the fixed fee.
Franchise owners — what you owe in each country The full guide to franchise owners what you owe in each country, with the fee fixed before any work starts.
Influencers & content creators — relief you're probably missing Its own page: influencers & content creators relief you're probably missing — mechanism, deadlines and published fees.
Civil & structural engineers — what you owe in each country Everything on civil & structural engineers what you owe in each country, at the same depth as this page.
Media & production companies cross-border tax Media & production companies cross border tax — the guide, the FAQ and the fixed fee.

Countries and corridors this work reaches

Peru tax for expats — country guide Peru tax for expats — the guide, the FAQ and the fixed fee.
India–UAE tax corridor The full guide to India UAE tax, with the fee fixed before any work starts.
Bermuda tax for expats — country guide Its own page: Bermuda tax for expats — mechanism, deadlines and published fees.
Croatia tax for expats — country guide Everything on croatia tax for expats, at the same depth as this page.
Uzbekistan tax for expats — country guide Uzbekistan tax for expats — the guide, the FAQ and the fixed fee.
Bahrain tax for expats — country guide The full guide to Bahrain tax for expats, with the fee fixed before any work starts.
Kazakhstan tax for expats — country guide Its own page: kazakhstan tax for expats — mechanism, deadlines and published fees.
Zimbabwe tax for expats — country guide Everything on zimbabwe tax for expats, at the same depth as this page.
Poland tax for expats — country guide Poland tax for expats — the guide, the FAQ and the fixed fee.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Files that look like this one

Case study 1

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 2

A Country-by-Country Report and Who Files It

The obligation sits with the group and the filing can fall on a surrogate where the parent's jurisdiction does not exchange. Establishing who files where comes before preparing anything.

Read how this one runs
Case study 3

An IRS Notice for a Year the Client Believed Was Settled

Most notices are proposals rather than assessments, and they carry a response window that is shorter than it looks. The engagement reads what is actually being proposed, gathers the support, and replies inside the window with the position rather than a request for time.

Read how this one runs
Case study 4

Ten Years of Missed Returns Filed as One Engagement

Filing many years at once is a sequencing problem: carry-forwards, instalments and credits from the earliest year feed the latest. Filing them out of order is what turns a recoverable position into an assessed one.

Read how this one runs
Case study 5

A Canadian Employer With Staff in the United States

Employing someone in the US creates federal and state obligations that begin with registration, not with the first return. Which states are engaged is decided by where the work happens rather than where the company is.

Read how this one runs
Case study 6

Treaty Relief Claimed on a Cross-Border Estate

The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.

Read how this one runs
Case study 7

A Foreign Affiliate Return Filed Years Late

The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.

Read how this one runs
Case study 8

Treaty Rate Refused Because the Paperwork Was Missing

A reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

Cross-border tax for sellers shipping worldwide: marketplace withholding, foreign registrations and inventory nexus handled before they become audits.

Marketplaces withhold, remit and report in their own right, so the tax position of a single sale is decided by where the stock sat, where the buyer was and which platform collected — not by where the company is registered. We reconcile the platform's own filings against the returns before either is submitted.

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Form 8621 — questions we are asked

Do I file Form 8621 even if no tax is owed?

Election obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. US persons holding shares in a foreign pooled investment, including anyone who bought ordinary index funds or mutual funds in the country they moved to.

What happens if I have missed Form 8621 for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form 8621 the same as the other reports I already file?

No. Reports and elects the treatment of a passive foreign investment company — most commonly a non-US mutual fund or pooled investment. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Do I pay tax twice on a foreign dividend?

Not at full rates if the relief is claimed. The paying country usually withholds at source, capped by treaty where one applies and the paperwork is in place; your residence country then taxes the dividend and credits the foreign withholding against its own charge. Where the withholding exceeded the treaty rate because no declaration was filed, the excess is recovered from the paying country, not credited at home. See the dividends article.

Should I use a branch or a subsidiary abroad?

A branch is the same legal entity operating in another country, so its profits and losses sit with the parent and it is taxed there as a permanent establishment. A subsidiary is a separate company, taxed in its own right, with dividends and withholding on the way home. Losses, repatriation cost and liability usually decide it, and the answer differs by country pair. See branch vs subsidiary.

Why are corporations double taxed?

Corporate double taxation happens because the company and its owners are separate taxpayers. The company pays tax on its profit; when the after-tax profit is distributed, the shareholder pays tax on the dividend. Canada softens this with the dividend gross-up and credit, which is meant to leave a shareholder roughly where they would have been earning the income directly. The United States taxes the C corporation and then the dividend, with no equivalent integration. See dividends to a foreign parent.

A named reviewer on every filing

Let us take Form 8621 off your desk

Send us the facts. You will get a scope and a fixed fee in writing, and nothing starts until you agree to both.

  • Your existing accountant keeps the domestic file
  • Re-quoted, never silently invoiced
  • Offices in India, the USA, Canada and the UAE

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068