
Is that fund a PFIC? Here's how to tell.
If it is a pooled, non-US investment — an OEIC, unit trust, investment trust or non-US ETF — the answer is almost certainly yes, and the US tax treatment is the worst in the code.
Figures on this page are stated for tax year 2025/26 UK · 2025 US. Thresholds change annually.

The test is mechanical, and merciless
A non-US company is a PFIC if 75% of its income is passive or 50% of its assets produce passive income. Investment funds pass by construction. Where the fund is domiciled decides everything: a US-domiciled ETF holding UK shares is fine; a UK-domiciled ETF holding US shares is a PFIC.
Check the fund's ISIN — starting 'US' is generally safe, 'GB', 'IE' or 'LU' generally isn't. The wrapper (ISA, GIA, even some pensions) doesn't change the answer.
- Fund domicile, not underlying holdings, decides status
- ISIN prefix is the quickest first check
- Pooled funds are PFICs; shares in an operating company are not, unless the company is itself mostly passive
Three questions about the holding
A quick orientation, not advice — real positions have edges this cannot see.
Answer all three questions to see the verdict.
Questions we get about this
Below the de minimis exception - $25,000 of PFIC stock, or $50,000 filing jointly, with no distribution or disposal that year - no Form 8621 is required at all. Above it, a small holding generates the same annual form as a large one.
It only affects the tax at stake, which is why small legacy holdings are often worth disposing of on administrative grounds alone.
Treat it as a starting point. If it says an obligation applies, the next question is what the filing actually involves and whether earlier years are affected.
If it says nothing applies, it is worth re-running whenever your circumstances change - a move, a property, a new account.
Broadly, a non-US company whose income or assets are mostly passive. In practice that captures most UK unit trusts, OEICs and investment trusts.
It is the fund's structure that matters, not the wrapper it sits in, so an ISA offers no protection.
Elections such as mark-to-market usually improve the outcome substantially compared with default treatment.
Timing matters, because elections generally have to be made in the right year rather than retrospectively.
It covers the common cases and will tell you reliably whether the basics apply to you. It is a guide, not a filing position.
Edge cases - trusts, business ownership, unusual residence patterns - can change the answer, which is why the result flags when a position is worth checking properly.
Related pages
- Free tool
Substantial Presence Test
Count your US days under the substantial presence formula, apply the weighting and exemptions, and see whether you are a US tax resident for the year.
- Glossary
PFIC: definition
Passive Foreign Investment Company — the US label that catches most UK funds, and why it hurts.
- Service
PFIC reporting
PFIC analysis and Form 8621 preparation for UK funds, ISAs and platform holdings: the election decided per fund, and the reporting cost cut where it can be.
- Service
Form 8621 (PFICs)
Form 8621 PFIC reporting: which UK funds qualify, excess distribution treatment, QEF and mark-to-market elections, and annual filing requirements.
- Pillar guide
Tax specialists for US and UK
What US and UK tax specialists handle that a general accountant does not: residence tests, treaty relief, FBAR, PFICs, pensions, property and catch-up filings.
- Pillar guide
Accountants for US and UK
How to choose accountants for US and UK tax: what each credential permits, how to verify it, what drives the fee, and when you do not need a specialist.
Further reading
- Is my fund a PFIC? How to check before you buy
Nothing on a fund factsheet says PFIC. The status comes from American law applied to a foreign company, so you have to work it out yourself.
- Your ISA is tax-free in the UK. The IRS disagrees.
The wrapper does not travel. Worse, most of what sits inside one is a PFIC, and PFIC treatment is punishing by default.
- Where Americans in Britain can actually hold investments
The hard part is rarely picking investments. It is finding an account that will take you, and a structure both tax systems treat sensibly.
Last reviewed · Figures stated for tax year 2025/26 UK · 2025 US. Thresholds and rates change annually — check figures against the current tax year before relying on them.
Got your answer and it looks complicated?
These tools are deliberately simple, and real positions rarely are. Send us what you found and we will confirm it properly.