Allocates gains and excess distributions from a passive foreign investment company across the holding period, applies the top rate to prior PFIC years, and compounds the §6621 interest charge daily. The output feeds Form 8621 Part V.
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Step 1
Load transactions
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Step 2
Review transactions
BUY amount = total cost basis. SELL amount = net proceeds; leave Lot blank for FIFO. DIST amount = distribution per unit. All amounts in USD (translate at the spot rate on each date). For an MTM election year, enter a SELL at the year-end value on Dec 31: under §1296(j), the first-year mark is taxed under §1291.
Date
Type
Fund
Lot
Units
Amount (USD)
§6621 underpayment rates (editable)
Quarterly individual underpayment rates. Years through 2026 are published IRS rates; rows in amber are assumptions, so update them when the IRS announces the rates.
Year
Q1 %
Q2 %
Q3 %
Q4 %
Step 3
Allocation and tax
Holding period per §1291(a)(3)(A) and §1223: it starts the day after acquisition and includes the sale or distribution date. Each day carries an equal share of the gain or excess. A distribution on the acquisition date is outside the holding period.
Prior PFIC years are taxed at the highest rate for that year (individuals: 37% from 2018, 39.6% for 2013–2017). Interest runs from the unextended due date of that year's return to the due date of the current-year return, compounded daily.
Excess distribution = this year's distributions over 125% of the average for the prior three years (fewer if held less than three years). None arises in the first year held. The excess is spread pro rata over the year's distributions. In a prior year's base, only the part of that year's excess included in income counts; the part allocated to earlier PFIC years is excluded (§1291(b)(2)(B)).
The current-year and pre-PFIC portions are ordinary income at your marginal rate. That tax is shown here as an estimate but belongs on the regular return, not in the deferred tax.
Simplifications: calendar-year taxpayer; amounts entered in USD (§1291(b)(3)(E) requires the 125% test in the distribution currency); partial-year distributions in the base are not annualized (§1291(b)(3)(C)), but a warning appears when that applies; no foreign tax credit, stock-split adjustments or QEF. Review all outputs before relying on them.