deferred interest charge Archives - U.S. Citizens and Green Card Holders Residing in Canada and Abroad

Updated July 30, 2026

Podcast: The #PFIC was born in 1986 and is alive and well at 40. An interesting life in progress.

A rare insight (based on original source) into what Congress thought they were doing in imposing punitive taxation on income not received. https://t.co/KQbCTZxcQP

— John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) July 30, 2026

PFICs were introduced as part of the 1986 tax reform. In order to understand the intent of the PFIC rules it is useful to read the general explanation of the tax reform act. The explanation starts at page 1021 of the document or page 1037 of the pdf. It is worth the read …

Archive.org

https://web.archive.org/web/20120507115421/https://www.jct.gov/jcs-10-87.pdf/

PDF of the complete notes surrounding the 1986 tax reform

jcs-10-87

A 1986 explanation of the new PFIC provisions before they were signed into law – What was Congress trying to accomplish?

jcs-10-87 PFIC section

John Richardson – Follow me on Twitter @Expatriationlaw

U.S. Citizens and Green Card Holders Residing in Canada and Abroad

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Tag Archives: deferred interest charge

General Explanation Of The 1986 Tax Reform Act – PFIC Edition