Sorry if this has been asked and answered already.
I'm a dual citizen living in Canada, and this is my first year dealing with PFIC reporting. I _believe_ that:
1. Canadian-domiciled mutual funds are PFIC's.
2. Canadian-domiciled ETF's (e.g. the _Canadian_ iShares ETF's traded on the TSX) are PFIC's.
3. US-domiciled ETF's (e.g. the _US_ iShares ETF's traded on the NYSE) are _not_ PFIC's.
Can somebody tell me if I'm right or not? thanks --
. charles
ETF's and PFIC's -- does "domicile" matter?
Moderator: Mark T Serbinski CA CPA
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cpcohen1945
- Posts: 1
- Joined: Thu Apr 12, 2012 11:29 pm
- Location: Canada
Correct on all points.
If you acquired the PFIC stock in 2011, you may simply make either the QEF or MTM elections on Form 8621. If 2011 was not the first year of ownership, you must either obtain a Private Letter Ruling to make a retroactive election or apply the rules of Section 1291 as if you disposed of the stock on Dec. 31, 2011.
If you acquired the PFIC stock in 2011, you may simply make either the QEF or MTM elections on Form 8621. If 2011 was not the first year of ownership, you must either obtain a Private Letter Ruling to make a retroactive election or apply the rules of Section 1291 as if you disposed of the stock on Dec. 31, 2011.
guess I'm replying to the reply. Is it difficult to get the private letter ruling. I was planning on filing 1291s on mutual funds/etfs purchased as long ago as 2004. This gets pretty expensive. If one gets the ruling do they also have to refile amended returns for all those years?
That might hold me back. But if refiling I guess the ruling would save money since the result would be "other income" against which I assume I could apply the extra FTCs I build up every year....which might be suffiicient to offset tax owing.
That might hold me back. But if refiling I guess the ruling would save money since the result would be "other income" against which I assume I could apply the extra FTCs I build up every year....which might be suffiicient to offset tax owing.