"Some" Canadian mutual funds "may" be PFICs http://t.co/HsyNHqYMBd – Does "some" include "all"? Exploring the logic of the classification
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 17, 2015
What is a PFIC?
The acronym “PFIC” stands for “Passive Foreign Investment Corporation”. For your reading pleasure, I refer you to:
S. 1297 of the Internal Revenue Code which defines what a PFIC is; and
S. 1291 of the Internal Revenue Code which describes the “default taxation” of a PFIC.
Assuming that all Canadian mutual funds are PFICs, the results are horrific. I have written about this problem in two separate submissions to the U.S Senate Finance Committee.