The exception, and its limits
The de minimis rule looks at the aggregate value of your PFIC holdings, not at each fund separately. Under $25,000, or $50,000 filing jointly, a filing exception can apply.
It is lost the moment you sell, take a distribution, or make an election. So it protects a small dormant holding, not an active one.
Do not confuse it with the other thresholds
Three separate regimes have three different triggers, and meeting one says nothing about the others.
- FBAR: foreign accounts together exceeding $10,000 at any point in the year.
- Form 8938: $50,000 at year end or $75,000 at any time if single and living in the US; $100,000 and $150,000 filing jointly; higher thresholds if you live abroad.
- Form 8621: the $25,000 / $50,000 PFIC de minimis above.
What to do next
This page explains a rule. It does not work out what you owe, and it is not US tax advice. Take your fund statements to a US CPA or an Enrolled Agent, because the analysis runs per fund, per year.