Is there a small-value exception that lets me skip filing Form 8621 for a PFIC?
Yes, a limited de minimis exception exists. Generally, if the total value of all your PFIC stock is $25,000 or less at year end ($50,000 for married filing jointly), and you received no excess distribution and made no qualifying disposition, you are not required to file Form 8621 for those PFICs, though the underlying accounts may still need FBAR and Form 8938 reporting. The thresholds and conditions are specific, and any distribution or sale can pull you back into filing. This exception helps immigrants who inherited or hold a tiny foreign fund position, but it is easy to breach. Do not rely on it without reading the current Form 8621 instructions on irs.gov, since the rules have nuances around indirect ownership and shareholder elections. When your foreign fund holdings grow, plan to unwind or elect proactively.
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