Updated 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
A 1986 explanation of the new PFIC provisions before they were signed into law – What was Congress trying to accomplish?
John Richardson – Follow me on Twitter @Expatriationlaw