This PFIC article library forms the central knowledge hub for Form 8621 compliance — covering §1291 excess distribution, FIFO partial dispositions, multi-lot tracking, historic FX basis, UNI carryforward, and MTM §1296. It provides a full learning path from beginner concepts to advanced PFIC engine mechanics used in pfic.xyz.
A step-by-step guide for individual filers covering data preparation, PFIC identification, §1291 basics, and how to generate audit-ready workpapers without relying on Excel.
PFIC fees aren’t driven by account size—but by time, risk, and multi-year §1291 calculations. Even small PFICs can generate substantial costs once distributions or dispositions occur.
A breakdown of the real workload behind Form 8621—from data cleanup to lot tracking— and why even a “simple” PFIC can take several hours of professional time.
Dividend reinvestments create new lots; partial sales trigger strict FIFO. These two events are the biggest drivers of exponential PFIC workload and audit risk.
The definitive reference on §1291 mechanics: 125% threshold logic, per-block allocations, historic §6621 interest, foreign-currency ordering rules, and Form 8621 mapping.
A realistic walkthrough of failure points when using Excel for §1291: rolling 3-year averages, lot-level structures, and FIFO dispositions.
A comprehensive guide to PFIC data cleaning: ghost transactions, unit-based fee deductions, PIE/PIR adjustments, ILAS unit cancellations, and internal ledger entries that should NOT be treated as PFIC dispositions.
A complete technical guide to computing PFIC Mark-to-Market under IRC §1296, including UNI rules, FIFO disposition, and compliant Form 8621 Part IV workpapers.
All articles in this section are original content based on the author's personal study, research, and hands-on experience with PFIC calculations, including Form 8621, Section 1291, and Section 1296. The content reflects independent understanding and technical analysis created specifically for pfic.xyz and is not copied or republished from external sources. It does not represent official guidance or professional tax advice.