PFIC exposure calculator
See what the default PFIC rules cost on a non-US fund held for years.
Open itThe streamlined procedures come in two tracks, and the difference between them is a penalty. Enter your days outside the United States for the last three years and the non-wilfulness facts, and this names the track and prices it.
Your facts
days
Full days, not part days. The year has to be one for which the return due date has passed.
days
Each year is tested separately; you need only one of the three to qualify.
days
A single qualifying year in the three is enough for the non-residency condition.
days
Three hundred and thirty full days under the current procedures. Editable in case it changes.
An abode is more than owning property. Both limbs — no abode and the day count — have to be met.
Negligence, inadvertence, a mistake, or a good-faith misunderstanding. Untick if it was not, because this is the wrong door in that case.
An open examination closes the streamlined procedures entirely.
The domestic track requires this. The foreign track does not, which is one of its advantages.
US$
Across the years in scope. Used to price the domestic track penalty.
%
The miscellaneous offshore penalty for the domestic track. Confirm the current figure before relying on it.
Which track
—
Position —
Eligible on these facts —
Non-residency condition —
Day threshold—
Years that meet it—
Best year, in days—
Days short in the best year—
Miscellaneous offshore penalty—
Blockers found—
What stands in the way
- Enter your figures above and this fills in.
Two tracks, and the day count is what separates them
Both tracks require the failure to have been non-wilful and neither is available once an examination is open. The difference is the non-residency condition: in any one or more of the three most recent years for which the return due date has passed, you had no United States abode and were physically outside the United States for at least 330 full days.
Meet it and you are on the foreign track, where the miscellaneous offshore penalty does not apply at all. Miss it and you are on the domestic track, which charges a penalty on the highest aggregate value of the unreported accounts and assets — and which additionally requires that returns were already filed for each year in scope. One year in three is enough to cross over, which is why the day count for each of the three years is asked separately.
Non-wilfulness is the real gate
The day count is arithmetic. Non-wilfulness is a statement of fact you sign, and it is the part that decides whether these procedures are the right route at all. It covers negligence, inadvertence, a mistake, and a good-faith misunderstanding of the law. It does not cover a decision not to report.
Where the conduct was not non-wilful, using the streamlined procedures is worse than doing nothing, because the certification itself is a statement to the authority. The alternative route exists for exactly that case and is a different conversation. If the honest answer to that checkbox is no, stop here and take advice before filing anything.
Worked example
A US citizen who has lived in Dubai for four years, with 365, 340 and 200 full days outside the United States in the three years in scope, no United States home, and 400,000 dollars across unreported accounts.
- Two of the three years clear 330 full days, and one is enough. With no United States abode, the non-residency condition is met.
- The foreign track applies, so no miscellaneous offshore penalty arises on the 400,000.
- Tick the abode box and the condition fails immediately, moving her to the domestic track and pricing the penalty on the full 400,000.
That one checkbox is the difference between nothing and a five-figure penalty on the same facts, which is why what counts as an abode is worth getting right.
What this calculator assumes
- The 330-day figure and the three-year window are the current conditions and are cited below. Both are editable.
- The penalty percentage for the domestic track is an input rather than an assertion. Confirm the current figure before relying on it.
- Non-wilfulness is a factual certification you sign, not something a calculator can determine. This tool records your answer and nothing more.
- Interest and the tax itself are payable on both tracks. Only the miscellaneous offshore penalty differs, and this tool prices that alone.
An estimate, not advice. This is an estimate built from what you typed, not advice on your file. Nothing here reads your documents, checks your treaty article or looks at the year you are actually in. Where the number matters, we agree a fixed fee in writing before any work starts.
Where these figures come from
- current procedures Streamlined filing compliance procedures — IRS
- current procedures US taxpayers residing outside the United States — IRS
- current procedures US taxpayers residing in the United States — IRS
Any figure prefilled in the panel above is stated with the year it belongs to and can be changed. Rates and thresholds move; a calculator that asks you for the current one stays right, and one that hides a guess does not.
Files that look like this one
Case study 1
Never Filed a US Return — and Only Just Found Out
Born in the United States, left as an infant, and told by a bank that the returns were owed all along. The work is sequencing: establish which years are actually open, choose the catch-up route on the facts rather than filing quietly, and claim the exclusions and credits that were never taken.
Read how this one runs
Case study 2
Catching Up From Inside the United States
The domestic route suits a filer who was resident in the US through the missed years, and it differs from the offshore one in what it asks for and what it costs. Choosing between them before anything is filed is the whole engagement.
Read how this one runs
Case study 3
One Employee in a State Nobody Had Registered In
A single person working from home can create payroll registration, withholding and sometimes an income tax filing for the company in that state. The review measures activity against each state's own threshold.
Read how this one runs
Case study 4
An Adjustment in One Country and No Relief in the Other
A pricing adjustment taxes the same profit twice unless the other country makes a corresponding one. The mutual agreement route is what produces that relief, and it is opened on a timetable set by the treaty rather than by either revenue authority.
Read how this one runs
Case study 5
A Pension Taxed Where the Treaty Did Not Intend
Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.
Read how this one runs
Case study 6
A Secondment Whose Paperwork Decided the Tax
Who employs, who directs and who bears the cost are the facts a treaty article turns on, and an assignment letter is where they are recorded. Drafting it with the tax position in view prevents an argument later.
Read how this one runs
Case study 7
A Student or Researcher Covered by a Treaty Article
Several treaties carry a dedicated article for students, trainees and visiting researchers that displaces the ordinary employment rules. Whether it applies turns on the purpose of the stay and the source of the funds, both of which are evidenced rather than asserted.
Read how this one runs
Case study 8
Moving Money Out of India and the Certificates It Needs
A remittance out of India needs its tax position certified before the bank will process it. The file establishes the character of the funds, produces the certification, and keeps the position consistent with the returns already filed.
Read how this one runsAll 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.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
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
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
Related-party purchasing, customs value versus transfer price, and foreign-affiliate structures put trading businesses inside the s.247 documentation rules.
Goods crossing a border move the tax question from income to indirect: registration thresholds, place of supply, the customs value and the transfer price between related entities all have to agree with each other. When they do not, the adjustment arrives from two authorities at once and each one uses the other's number.
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
Who We Serve:
Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
Who We Serve:
Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Who We Serve:
