Private beta · For US taxpayers with European ties
Hold European indices without the IRS PFIC nightmare.
Direct indexing for US-connected expats. Track the Euro Stoxx 50 or MDAX by owning the underlying stocks directly — no fund wrappers, no Form 8621 per fund, fully automated.
- Own the actual companies, in your own account
- Automated, low-cost rebalancing
- Target fee: 0.25% per year
The problem
Your European fund is probably a .
Under IRC §1297, almost every non-US pooled fund — UCITS ETFs, European mutual funds — is a Passive Foreign Investment Company. For US taxpayers, that's expensive.
Punitive tax treatment
Gains can be taxed at the highest ordinary rate plus an interest charge, instead of long-term capital gains rates.
Form 8621, per fund, per year
Each PFIC holding typically needs its own filing — and cross-border CPAs charge accordingly.
Blocked from US ETFs too
Living in the EU? PRIIPs/KID rules often stop you buying VOO or VTI at a European broker. You're stuck in between.
What it costs you
The PFIC penalty, in dollars.
Set your situation and compare what the same European index exposure leaves you with after US tax, held four different ways.
Holding European ETFs could cost you $0 over 20 years versus owning the stocks directly.
After-tax value at the end of the period, after fees, taxes and Form 8621 preparation ().
Join the waitlistAssumptions & method
- Direct ownership: 3% dividend yield taxed yearly as qualified dividends; remaining gain taxed once at long-term capital gains rates when sold at the end. Apta at a 0.25% target fee; a cross-border wealth manager at 1.25%.
- UCITS ETF, mark-to-market election (the usual choice for listed ETFs): each year's gain is taxed as ordinary income, with no deferral and no capital gains rate. Fund fee 0.15%.
- UCITS ETF, no election (default §1291 rules): the gain at sale is spread evenly over the holding period. Each prior year's share is taxed at the top 37% rate plus an IRS interest charge (modelled at 7%/yr, compounded).
- The 3.8% Net Investment Income Tax applies in the 32% bracket and above. Form 8621 preparation is assumed at $300 per fund per year, a typical cross-border CPA fee.
- The model ignores state tax, foreign taxes and foreign tax credits, withholding, currency moves and market volatility. It is an illustration, not tax advice.
How it works
Own the index's stocks, not a fund.
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1
Pick an index
Start with the Euro Stoxx 50 or MDAX. More indices as the beta grows.
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2
We buy the components directly
Shares of the actual operating companies are held in your own segregated brokerage account — your name, your title.
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3
Automated rebalancing
Orders are blocked together for low commissions and allocated to each account. Holdings are screened to filter out companies that could themselves be PFICs.
Why this exists
Built by an expat developer, for peers.
I'm a US taxpayer with deep ties to Europe. After paying for one too many Form 8621s, I wrote software to hold the MDAX directly — buying the top components and rebalancing automatically. It runs on my own money today.
I'm now gauging whether others in the same situation want this too. This is an early-stage private beta for a small cohort — not a launched product. Joining the waitlist is free, carries no obligation, and I'll never ask you for money or card details here.
FAQ
Questions
Does holding individual European stocks avoid PFIC?
Ordinary operating companies (think SAP, Siemens, LVMH) generally aren't PFICs — the regime targets entities whose income or assets are mostly passive, like funds. A small number of holding-company-style stocks could qualify, so the engine screens those out. This isn't tax advice; confirm your situation with your own tax advisor.
Do you track the index exactly?
The beta holds a sample of the largest components (e.g. the top 30 of the MDAX) to keep trading costs near zero. That means small, transparently reported differences from the headline index.
Where is my money held?
In your own segregated account at a major, regulated broker. The plan is that you own the shares directly — the software never pools client money.
What does joining the waitlist commit me to?
Nothing. It's free, there's no obligation, and no payment information is ever collected here. You may get a short email asking whether you'd like to chat.
When will it launch?
No date yet. Onboarding external investors requires the right regulatory structure, and this page exists to find out whether there's enough interest to build it properly.
Keep your European exposure. Drop the PFIC paperwork.
Join the private beta waitlist. Free, no obligation.
Join the waitlist