To support U.S. persons investing in our Funds, Picton Mahoney Asset Management provides tax information in the form of PFIC Annual Information Statements for selected funds.
Generally, U.S. investors are required to file Form 8621 to report their investment in a PFIC. The PFIC Annual Information Statement enables U.S. investors to make the Qualified Electing Fund (QEF) election when they file Form 8621.
A Passive Foreign Investment Company (PFIC) is defined as a non-U.S. corporation (or a non-U.S. entity treated under U.S. tax principles as a corporation) where 75% or more of its gross income is passive income, or at least 50% of the corporation's assets produce or are held to produce passive income. Canadian mutual funds are generally viewed as PFIC for U.S. tax purposes and are subject to U.S. PFIC rules. "U.S. persons" holding non-registered Canadian mutual funds are likely subject to the Passive Foreign Investment Company (PFIC) rules and are required to report income from each PFIC when U.S. income tax returns are filed. A "U.S. person" is defined as a U.S. citizen, U.S. resident, green card holder, or an individual who meets the Substantial Presence test under the Internal Revenue Code (and does not qualify for the Closer-Connection Exception). U.S. resident corporations, partnerships, estates and trusts may also be defined as "U.S. persons." The PFIC rules are very complex, and we suggest you seek advice from a U.S. tax advisor on how these rules may apply to your situation.
You can make Qualified Electing Fund (QEF) elections on your 2015 U.S. income tax returns. The PFIC Annual Information Statement contains the information investors need for PFIC reporting for purposes of the QEF election. Please consult with your tax advisor to discuss any PFIC-related tax implications The Picton Mahoney Funds we are providing 2015 PFIC Annual Information Statements for can be found below. The statements are now available and can be printed by clicking on each fund name and by downloading the PDF. For certain funds, we are also providing IRS Form 8937, which contains certain information that may be required when filing U.S. tax returns. Please note that any U.S. federal tax information contained herein is not intended or written to be used and cannot be used for the purpose of (i) avoiding penalties that may be imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
For the 2015 tax year, Picton Mahoney Asset Management is providing PFIC Annual Information Statements for the following funds:
2015 PFIC Annual Information Statements
2015 IRS Form 8937
If you have any questions regarding PFIC Annual Information Statements, please contact our client services team at 416-955-4108 or email us at firstname.lastname@example.org