PFIC · what the default regime costs
$39,135
₹37.2 L at ₹95 / $

US tax and interest on a $60,000 gain, held 15 years — that is 65% of the gain, of which $16,785 is interest rather than tax.

The three regimes

Same position, same gain, three different sets of rules. The default applies when neither election is in place — which is the usual situation, because both elections generally had to be made for the first year the position was held.

§1291
Default regime
$39,135
₹37.2 L
65% of the gain · $16,785 of it interest
Gain spread back across every year held. Each prior year taxed at that year's top ordinary rate, plus an interest charge running from that year's filing deadline.
§1296
Mark to market
$19,200
₹18.2 L
32% of the gain
Unrealised appreciation included each year as ordinary income. Requires the holding to be marketable stock, and no interest charge arises.
§1295
Qualified Electing Fund
$9,000
₹8.6 L
15% of the gain
Fund earnings included annually as they arise; the disposition is then a capital gain. Requires an annual information statement from the fund.

What this screen cannot tell you

Not a menuThe two comparison figures are what this position would have cost under those regimes. They are not choices available today. A Qualified Electing Fund election needs an annual information statement from the fund, which many non-US pooled funds do not produce at all; a mark-to-market election needs the holding to be marketable stock within the meaning of the regulations. Making either one late generally requires a purging election, which has its own cost and is not modelled here.
Also outside this screenDistributions received while holding, each of which carries its own throwback. Years before the fund met the PFIC tests. US state income tax, which is material in several states. Anything about characterisation rather than timing. And every one of the reporting obligations that attaches to holding one of these, which is a filing question rather than an arithmetic one.

The working

Show the year-by-year allocation

Under the default regime the gain is allocated ratably across every day of the holding period. The slice falling in the year of disposition is ordinary income at your own marginal rate. Every earlier slice is taxed at the highest ordinary rate in force for that year — not your rate, and not today's rate — and carries interest as though the tax had been underpaid since that year's filing deadline.

YearDaysShare of gainRateTaxInterestTotal
2011364$3,73835.0%$1,308$2,301$3,609
2012366$3,75835.0%$1,315$2,076$3,392
2013365$3,74839.6%$1,484$2,093$3,577
2014365$3,74839.6%$1,484$1,859$3,343
2015365$3,74839.6%$1,484$1,640$3,124
2016366$3,75839.6%$1,488$1,439$2,928
2017365$3,74839.6%$1,484$1,244$2,729
2018365$3,74837.0%$1,387$996$2,383
2019365$3,74837.0%$1,387$840$2,227
2020366$3,75837.0%$1,391$696$2,087
2021365$3,74837.0%$1,387$558$1,945
2022365$3,74837.0%$1,387$431$1,818
2023365$3,74837.0%$1,387$312$1,699
2024366$3,75837.0%$1,391$201$1,592
2025365$3,74837.0%$1,387$97$1,484
2026365$3,74832.0%$1,199—$1,199

Assumptions and simplifications

The QEF and mark-to-market figures are what this position would have cost under those regimes, not options available today. Both are elections that generally had to be in place for the first year of the holding period, and both have eligibility conditions a non-US pooled fund may not meet at all.

Interest is compounded annually at a flat 7.0%. The statutory rate floats quarterly and compounds daily, so a real charge on a holding period this long comes out somewhat higher than the figure shown.

The holding period spans 3 different top ordinary rates (35.0%, 39.6%, 37.0%). Each year's slice is taxed at the rate in force for that year, not at today's rate.

Dates are modelled as whole calendar years — bought on 1 January of the purchase year, sold on 31 December of the disposition year. A real acquisition date shifts the first and last slices, not the shape of the result.

The rupee figures use at ₹95 / $, an assumption you set rather than a live rate.