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PFIC Rules on Indian Mutual Funds: Why They Hurt

Indian mutual funds, ULIPs, and many Indian investment products are PFICs under U.S. tax law, and PFIC tax is brutally punitive. Here's what to do.

By Aparna Devalla, CPA3 min · 5 slidesUpdated June 15, 2026

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What Makes Something a PFIC

  • Passive Foreign Investment Company (PFIC) test: foreign corporation where (a) 75%+ of gross income is passive, OR (b) 50%+ of assets produce passive income.
  • Virtually all foreign mutual funds, including Indian mutual funds, qualify as PFICs.
  • Most foreign hedge funds, foreign ETFs, foreign life insurance with investment components: also PFICs.
  • Holding even ONE share triggers PFIC reporting (Form 8621).

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Educational content, not tax, legal, or accounting advice. Confirm with a CPA before acting.

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