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  1. US expat tax filing and German pension funds

    @Straightpoop   Thank you for your detailed explanation, as I have been wrecking my brain about PFICs for some years now. I agree with your assessment that the above mentioned fondsgebundene Rente would not qualify as a pension under DTA Article 18A, as really only pensions under the Betriebsrentengesetz would qualify for that. I am curious about your conclusion though that it's not a PFIC because the OP has or likely has no direct ownership in the funds/units. Could you elaborate a little more on that? It's an entirely new approach to me and I would like to get an onboard, but I cannot reconcile it so far.