Services
PFIC reporting
Form 8621 analysis for UK funds, ISAs and investment platforms held by US persons — the most technical form in expat filing.
The funds you already hold, reported properly.
Most UK funds, index trackers and ETFs are Passive Foreign Investment Companies to the IRS — including everything inside a Stocks and Shares ISA. The default treatment is punitive.
The right election, made in the right year, is usually the difference between a manageable outcome and a painful one.
What we do
01
Holdings analysis
Working out which of your funds are actually PFICs, which is rarely obvious from the fund literature.
02
Form 8621 preparation
One form per fund per year, prepared with the computations behind it.
03
Election modelling
QEF and mark-to-market elections compared against the default regime before anything is filed.
04
Restructuring advice
Where the reporting burden outweighs the holding, practical options for moving to compliant alternatives.
Why us
An ISA is not a shelter here
The UK treats an ISA as tax-free. The IRS does not recognise it, and taxes what is inside it under the PFIC regime.
We tell you plainly what a holding costs to keep, so the decision to restructure is yours and informed.
When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.
View our peopleFrequently asked
Is my ISA really a problem?
The wrapper gives no US relief, and funds held inside it are generally PFICs. Cash ISAs are simpler; Stocks and Shares ISAs usually are not.
How many forms will I need?
Generally one Form 8621 per PFIC per year. A diversified portfolio can mean a great many, which is often the argument for consolidating.
Is my ISA a PFIC?
The ISA is a wrapper rather than an investment. What matters is what is inside it — most UK funds and investment trusts held within one are PFICs.
Why is the default treatment so punitive?
The excess distribution regime taxes gains at the highest rate with an interest charge for deferral. It is designed to remove any advantage from holding a non-US fund.
What is a QEF or mark-to-market election?
Alternatives to the default regime that are usually far better, but they depend on information the fund may not provide, and on being made in the right year.
Should I just sell everything?
Often the cleanest answer, particularly before becoming a US taxpayer. Once held, disposal has its own consequences, so the sequencing matters.
Form 8621 analysis for UK funds, ISAs and investment platforms held by US persons — the most technical form in expat filing.
Key contact
Tell us what you are trying to solve and we will put the right specialist on the call.
Client enquiries
US–UK tax team
Other services
All services
Stay informed with our latest publications and insights.
Latest
Read our insights
Specialists who work in both tax systems every day, not one with a view on the other.