What Is a PFIC Annual Information Statement and How Do I Get One?

A PFIC Annual Information Statement (AIS) is a document the foreign fund provides to U.S. shareholders that contains the data needed to make a Qualified Electing Fund (QEF) election on Form 8621. It reports the fund’s ordinary earnings and net capital gains on a per-share basis. Without an AIS, you cannot make a QEF election and are stuck with the punitive default Section 1291 excess distribution regime (IRS: Form 8621 Instructions).

• QEF election requires an AIS to report annual income inclusions at favorable rates
• Mark-to-market election does not require an AIS (only requires the PFIC stock to be “marketable”)
• Section 1291 default applies when neither election is made, taxing excess distributions at the highest ordinary rate plus an interest charge

Why most expats cannot get an AIS:

• Foreign funds are not required to provide one: the AIS is a voluntary accommodation for U.S. shareholders, and most non-U.S. fund managers do not produce it
• U.S. shareholders are a small minority: foreign funds serving local investors have no incentive to create U.S.-specific tax reporting
• Some large funds cooperate: a few global fund families (Vanguard Ireland, iShares UCITS) have begun providing AIS-equivalent data, but this is the exception

What to do if you cannot get an AIS:

• Mark-to-market election: if the PFIC is publicly traded on a qualifying exchange, this is the best alternative to QEF
• Request the data directly: write to the fund administrator asking for per-share ordinary earnings and net capital gains; some will provide it informally
• Reasonable estimate: IRS regulations allow shareholders to use reasonable estimates of the PFIC’s income in some circumstances, but this is aggressive and requires documentation
• Sell and reinvest in U.S. funds: the cleanest long-term solution is to exit foreign funds and invest through U.S.-domiciled ETFs and mutual funds, which are not PFICs

For more, see our PFIC Reporting Guide.