Nomura Securities JPY balance is a PFIC?


I have come to learn that any JPY I deposit to my Nomura Securities account is automatically moved into MRF.

It looks like when you deposit JPY, it goes from the "預り金" column almost immediately (within a day or two) to the "MRF" column.

This sounds like a PFIC. This is most definitely a PFIC…

Not only is it a PFIC, but the interest rate is horrible. (0.086%)

Questions:

  1. If I deposit JPY and buy stocks and make sure I don't hold a balance under the MRF column for too long (like less than a day or two), can I avoid the reporting requirements? (FYI It seems like the interest accrues daily)
  2. What are the details of the rules that would allow such a reporting requirement to be waived? (is it based on a total amount invested at any one point? is it based on a total amount of unrealized profit? etc.)

… I'm starting to regret making a Nomura account now.

Edit: Do I need to worry about PFIC reporting here? I won't have >$25,000 worth of JPY at the end of the tax year, and I doubt they'll suddenly give me 125% excessive distributions in their super low interest fund… I also will try to keep the balance 0 as much as possible so I won't even have a chance to get an excessive distribution. Am I playing with fire? Does 125% mean that their previous annual rate of 0.086% would become 0.1075%, and if I get a lump sum distribution of over 0.1075% of my holdings, I would trigger reporting? (I doubt that would happen, but I just want to understand)

Edit 2: Upon further research, it seems like at the end of each tax year I will calculate my total PFIC holdings, and for each PFIC I calculate the total distributions for the year. If the holdings is less than $25k ($50k filing joint) at the end of the tax year, and the total distributions for any given PFIC does not meet or exceed 125% of the average of the previous 3 years' annual distributions… then I am exempted from filing PFIC papers as long as I don't opt into any Mark-to-market or QEF stuff (Which I won't). It seems as long as I don't keep more than 420k JPY for a day, I shouldn't get any distributions at all… this still feels like playing with fire though… I should watch my account like a hawk to make sure I don't get any 1 yen payouts… move things over to the Nomura Shintaku bank account attached to my brokerage account… ugh why is this so hard. lol

by ToTheBatmobileGuy

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