How Much Does Form 8621 Cost for Canadian Funds?

Form 8621 costs nothing to file with the IRS, but it’s filed per fund, per year, so the bill scales with your fund count. Published prices we found run from $69 a form (MyExpatTaxes, on its reviewed plan) to $300 for a fund that paid distributions (Greenback). Taxes for Expats bills the default excess-distribution regime by the hour. Ours is $400 per fund per year beyond those in a package, and Cross-Border Executive includes up to two. Both are starting points, fixed in writing at the Diagnostic. See what cross-border tax help costs for the rest of our rate card.

When is Form 8621 required for Canadian funds?

Generally, every year you hold a PFIC directly or indirectly, one form per fund. The Form 8621 instructions list five triggers, including receiving certain distributions, selling shares, reporting a QEF or mark-to-market election, and the annual report under section 1298(f). A Canadian mutual fund or ETF held in a non-registered account is the common case; the PFIC guide explains why they’re caught.

There are two useful exceptions. You don’t complete the annual Part I report for a section 1291 fund if your total PFIC stock is $25,000 or less on the last day of the year ($50,000 on a joint return) and you had no excess distribution or sale from that fund. And in certain situations, a member of an arrangement treated as a foreign pension fund under a US tax treaty doesn’t complete Part I for PFICs held inside it, under Regulations section 1.1298-1(c)(4).

That second rule is the one people ask about for RRSPs. The instructions say it applies “in certain situations,” so whether funds inside your RRSP are covered is a question to confirm on your facts.

What does it cost to file Form 8621 yourself?

No fee. It’s attached to your return and filed by its due date. For individuals, the IRS counts the form’s time inside the Form 1040 estimate. For filers other than individuals and businesses, it estimates 16 hours 58 minutes of recordkeeping, 11 hours 24 minutes learning the law or the form, and 20 hours 34 minutes preparing and sending it, almost 49 hours a form.

That figure isn’t written for individuals, but it shows why few people do this themselves. Under the default regime, the instructions define an excess distribution as the part of this year’s distributions above 125% of the average of the 3 preceding years, determined per share and allocated to each day you held the stock. That means distribution history and purchase dates for every lot, for every fund.

If you file through software, the form still needs those numbers. The software does the arithmetic; it doesn’t rebuild missing purchase history or choose an election for you.

What do firms charge per Form 8621?

Published per-fund prices we found run from $69 (MyExpatTaxes, reviewed plan) to $300 for a fund that paid distributions (Greenback). The catch is the regime and the payouts: Greenback and Bright!Tax charge more when a fund paid distributions, and Taxes for Expats bills section 1291, the default for most Canadian funds, by the hour.

Provider and line	Published price	Scope, per the provider’s page
Taxes for Expats, PFIC income (section 1296 or 1293)	$200 for one, $150 for each after one	Mark-to-market or QEF reporting
Taxes for Expats, PFIC income (section 1291)	Billed by the hour	The default excess-distribution regime
MyExpatTaxes, Base plan (software)	$149 per form	Self-prepared in its software
MyExpatTaxes, Reviewed plan	$69 per form	Reviewed by a US tax professional
Greenback, Form 8621	$200 per form, $300 if the fund made distributions	Flat fee per form
Bright!Tax, Form 8621	$170 per fund, $280 if there were distributions	Flat fee per fund
Blue Cloud, Form 8621	$400 per fund per year	Beyond any included in a package
Blue Cloud, Cross-Border Executive package	from $2,745 per person	Includes up to two PFIC filings

Firm prices were checked on their own pages on October 18, 2026, and MyExpatTaxes figures are its USD prices. They’re each provider’s list price for its own scope.

How does the PFIC regime change the price?

It decides what each form has to calculate. Mark-to-market compares year-end value with your adjusted basis and is close to mechanical once set up. A QEF inclusion needs the fund’s ordinary earnings and net capital gain for the year. The default section 1291 regime needs distribution history and a daily allocation, which is why Taxes for Expats bills it by the hour. Greenback and Bright!Tax charge more when a fund paid distributions.

• Section 1291 (no election). Any excess distribution and any gain on a sale is spread across your holding period, so a sale of a long-held fund is the most expensive form you’ll file.
• QEF election. A shareholder includes its pro rata share of the fund’s ordinary earnings and net capital gain each year, so the fund’s figures are needed annually.
• Mark-to-market election. Available only for “marketable stock,” and the instructions say the first year of the election may still be reported under section 1291 rather than Part IV.
• Fund count. Four funds is four forms. The single biggest saving is usually fewer funds, which is where PFIC-safe investments come in.
• Catch-up years. If you’re behind, PFIC computations are the slowest part of a streamlined file with Canadian funds, and the streamlined cost guide covers how they move that price.

What happens if I don’t file Form 8621?

The return stays open. IRC 6501(c)(8) says that where information required under section 1298(f) isn’t reported, the time to assess tax on the related return, event or period doesn’t end until 3 years after the information is furnished. If the failure was due to reasonable cause, that’s limited to the related items.

We didn’t find a separate dollar penalty for a missed Form 8621 in section 1298 or in the December 2025 instructions, which describe the form’s own penalties only in general Paperwork Reduction Act terms. The cost of not filing is the open statute plus whatever tax and interest the section 1291 rules produce when the form is finally prepared. A missed 8621 can also sit next to other missed forms that do carry penalties, like the FBAR.

What should I do next?

List every non-registered fund and ETF you hold, with its purchase dates, the distributions you’ve received and whether anyone ever made an election. Add up the year-end values to see if you’re under the $25,000 or $50,000 exception. Then decide whether to keep holding Canadian funds at all before you pay for another year of forms.

• The PFIC guide covers which Canadian funds are PFICs.
• The cross-border tax return cost guide shows how PFIC forms fit into a full annual filing.

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.