Form 8621 — PFIC · budget-friendly, fixed fee

Google Rating 5.0Clutch Rating 5.0

Reports applicable passive foreign investment company holdings, distributions and dispositions, and records relevant elections and computations. 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.

+1 (416) 619-0068 See fixed fees
  • 15+Years of the founder's cross-border experience
  • 18,000+Clients served across our offices in India, the USA, Canada and the UAE
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
Google Rating 5.0Clutch Rating 5.0

Secure a fixed quote

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
  • Google rating 5.0 out of 5
What this form covers

Reports applicable passive foreign investment company holdings, distributions and dispositions, and records relevant elections and computations.

Who must review this filing?

US persons with direct or indirect PFIC interests must examine the reporting triggers and exceptions in the IRS instructions. Distributions, disposition gains, QEF or mark-to-market reporting, elections and annual reporting can each matter. A foreign fund’s marketing name alone does not establish PFIC status or the filing requirement.

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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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

in US dollars, fixed and 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.

Form 8621: reporting first, election choice second

Identify each holding and its ownership chain, establish whether it meets the PFIC rules and collect purchase, sale and distribution records. Check whether an exception applies to the reporting obligation being considered; an exception for one purpose should not be treated as relief from every other trigger.

A QEF computation depends on the required fund information. Mark-to-market treatment has its own stock-eligibility and election conditions. Where neither applies, examine the default regime using the actual holding history. Prepare the parts required for that position, reconcile them to the US return and retain the election and basis records for later years.

When to file or apply

Generally attach Form 8621 to the required US income tax return by its due date, including an applicable extension. The instructions prescribe a separate filing route when no income tax return is required. Election timing and eligibility need their own review; annual reporting is not simply an optional election.

What a missed filing or application can affect

An omitted PFIC form can affect the assessment limitation period and leave the taxpayer with unresolved reporting obligations. The default tax-and-interest rules can also differ materially from QEF or mark-to-market treatment. Do not assume a missed form has no consequence merely because an election was not made or the investment paid no cash.

Two foreign funds need separate decisions

Illustration: a US person owns two non-US funds. Both must be classified before choosing the reporting treatment.

ItemReview or illustrative amount
Fund ACheck its PFIC status and any qualifying annual information statement
Fund BCheck PFIC status and whether the stock meets mark-to-market conditions
TransactionsReconcile distributions and sales for each holding
Filing decisionApply the relevant reporting triggers and exceptions to each PFIC

A single portfolio balance does not decide all filing or election questions. This example deliberately makes no return calculation without the fund information and holding history needed to support it.

Official filing guidance

Reviewed against the issuing authority on 24 October 2026. Apply the instructions for the reporting period involved.

How we prepare your filing

We review your documents, identify the applicable reporting period and filing position, and agree a fixed fee in writing before work starts. Preparation includes reconciliation of the supporting records and a review before the filing is approved.

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

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
$349in US dollars, fixed 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
Foreign asset & information reporting
$349in US dollars, fixed before work starts

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

See this fee page
Individual tax filing
$349in US dollars, fixed 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
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

Named practitioners, each with the countries and the part of a cross-border file they carry, across India, the USA, Canada and the UAE. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE, Legal Quotient Consultants
Udit Gupta
Director, International tax, cross-border tax and transfer pricing: USA, Canada, India and UAE

CA (India), CA (Malaysia)

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

Udit Gupta on LinkedIn

Raghav Gupta, UAE and India international tax, cross-border tax and transfer pricing, Legal Quotient Consultants
Raghav Gupta
Director, UAE and India international tax, cross-border tax and transfer pricing

FCA (India)

Files that run between the UAE and India: residence, the treaty position, and the benchmarking and documentation behind intercompany pricing.

Raghav Gupta on LinkedIn

Vinayak Indolia, CFO services for Canada and India, Legal Quotient Consultants
Vinayak Indolia
Director, CFO services for Canada and India

CPA (Canada), CA (India)

CFO services for businesses in Canada and India: the tax position and the finance function made to agree, structure reviews, intercompany policy, and the reporting a board can act on.

Vinayak Indolia on LinkedIn

Meet the whole team

Files that look like this one

Case study 1

Index funds bought after a move abroad

A US citizen who had moved abroad opened an ordinary brokerage account in the new country and bought the index funds on offer there. Nobody had mentioned that each one was a foreign pooled investment for US purposes. We identified which holdings were in scope, obtained the fund-level reporting where it existed, and made the election that fitted what each fund actually published. The engagement produced a return with elections attached from the first year of ownership, and a short written note the client could hand to their investment adviser before buying anything further.

Case study 2

Fund units inherited from a parent overseas

A client inherited an account holding several pooled funds from a parent who had lived overseas. The statements were in another currency, the acquisition history predated the client entirely, and the platform had switched the units between share classes more than once. The work was largely evidential: establishing when the client's own holding period began, which platform events were disposals and which were not, and what the funds published. The engagement produced a documented holding position for each fund and a filing that set out how every figure had been arrived at.

Case study 3

Choosing an election before the first return was filed

A new client was about to file a first US return after taking up a role abroad, and had already bought into local funds. Because nothing had yet been filed, every election remained open. We compared what each fund publishes against what each election requires, and found that the same choice did not suit the whole portfolio. The engagement produced elections made holding by holding, in the first year of ownership, and a written record of why each one was chosen, which matters far more later than it appears to at the time.

Case study 4

Platform switches that turned out to be disposals

A client's adviser had been rebalancing a portfolio of pooled funds, moving money between them as routine housekeeping. For US purposes several of those movements ended holding periods and started new ones. We reconstructed the sequence from the platform's own transaction history, matched it to the reporting each fund made available, and worked out where the default regime had been triggered and where an election had survived. The engagement produced a corrected set of schedules and a note to the adviser about which routine actions carry a consequence.

Case study 5

Reconstructing holding periods from incomplete statements

A client had changed brokers twice and kept only annual summaries. The default regime measures across the whole period a holding is owned, so the missing acquisition dates were the engagement. We wrote to the former platforms, rebuilt the chronology from contract notes and bank records, and documented what could not be evidenced along with the assumption used in its place. The engagement produced a filed position with its own audit trail, so that if the dates are ever questioned the reasoning sits on the file rather than in somebody's memory.

Case study 6

Working out whether a wrapper changed the analysis

A client held pooled funds inside an arrangement sold locally as a retirement product, and wanted to know whether the wrapper altered the US treatment or merely hid it. We read the governing documents rather than the brochure, established who owned the underlying units and on what terms, and set out where the analysis turns. The engagement produced a written position on the ownership chain, a decision on what had to be reported, and a plain statement of the point on which reasonable advisers could differ.

Case study 7

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 8

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

All case studies — every published engagement in one place.

Where we deliver this work

Each of these carries its own guide, pricing pointers and FAQ.

Where the work is delivered
More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

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

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
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
Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
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
Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
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
Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
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
Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Cross-Border Corporate Tax
Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
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
NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
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
T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
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
Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
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

Is Form 8621 only an election form?

No. It also reports PFIC information, distributions and dispositions. Reporting can be required even when the taxpayer is not making a new election.

Does every non-US mutual fund automatically require filing?

Establish the fund’s tax classification, the investor’s status and the applicable reporting triggers and exceptions. The investment label alone is insufficient.

Can I choose QEF or mark-to-market without checking eligibility?

No. Each route has information, eligibility and timing conditions. Compare the available positions using the holding’s own records.

Tax terms explained
Terminal returnDouble taxationBona fide residence testWithholding certificateCost contribution arrangementPillar TwoProfit level indicatorBusiness purpose testEconomic substanceReverse chargeMATClearance certificateCompliance calendarFC-GPR Browse the full A–Z glossary

Forms and situations related to Form 8621

Nearby pages

All US & FinCEN formsForm 1041 — trust and estate return with foreign assetsForm 8843 — exempt individual statementForm 8865 — foreign partnershipForm 14653 — non-resident certificationForm 8288-C — section 1446(f) withholdingForm 8840 — closer connection (snowbirds)

Connected engagements

Canadian receiving a foreign giftHow to avoid double taxationTreaty shopping & beneficial ownershipAdvance rulings — IndiaSplit-year (part-year) residency in CanadaNRI selling property in India

Short answers

Who files Form 8621?What is the late filing penalty for Form 8621?
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.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 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