My foreign-owned LLC holds a small position in a Luxembourg-domiciled fund — does that pull in PFIC reporting?
I'm a non-resident alien sole owner of a New Mexico LLC (disregarded). For idle cash management, the LLC put about $25,000 into a Luxembourg SICAV (a mutual-fund-style vehicle). I'm not a U.S. person and don't file a U.S. return for myself, but I do file Form 5472 + pro forma 1120 for the LLC. Do PFIC rules apply to the LLC, to me, or to neither in this fact pattern?
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