How do the QEF and mark-to-market elections change how my PFIC is taxed?

Both elections are escape hatches from the punitive default PFIC regime, but each has strict requirements. A Qualified Electing Fund (QEF) election lets you report your share of the fund's annual ordinary income and capital gains as they accrue — much like a US fund — preserving long-term capital-gain treatment. The catch: it only works if the fund provides an annual PFIC Information Statement, and almost no Indian fund does, making QEF rarely available. Mark-to-market (MTM) is available for PFICs with regularly traded shares: you report annual paper gains as ordinary income and can deduct losses only up to prior gains. MTM avoids the interest charge but converts everything to ordinary rates with no long-term benefit. Both must be elected timely. Given how hard these are to use, most advisors simply tell US residents to avoid Indian funds entirely.