Tax consequences for a Japanese person getting a US green card

I'm thinking through the consequences of J-partner someday becoming J-spouse and picking up a US green card.

From what I can tell, this really sucks for J-partner, right? Essentially all of her investments would be considered PFICs, meaning J-partner either has to totally accidentally forget to tell America about things, or has to sell everything (needlessly realizing cap gains) and then live the same IBKR world at the rest of us.

iDeCo becomes a trap that can only hold cash (I'm setting aside the dissenting takes on iDeCo being PFIC-immune).

Selling PFICs in the NISA blows up accumulated contribution limits.

I shudder to think about how unwinding a Japan structured "insurance" investment product works…

Am I missing any sort of grandfathering or grace period for newly-minted green card holders, or is it really as drastically disruptive as it seems? Are there any mitigation strategies to apply ahead of time, other than encouraging J-partner to start investing like an American now?

by ImJKP

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