According to Odaily, Simon Gerovich, CEO of the Japanese-listed company Metaplanet, which employs a Bitcoin reserve strategy, announced on the X platform that the company is assessing whether it might be classified as a Passive Foreign Investment Company (PFIC) by the U.S. Internal Revenue Service (IRS) for its American shareholders. Under current IRS guidelines, a company is considered a PFIC if 75% or more of its income in a tax year is passive, or if 50% or more of its average assets produce or are held for the production of passive income.
Metaplanet believes that most of its goodwill can be classified as active assets. However, the IRS may disagree and could potentially classify Metaplanet as a PFIC for the 2025 tax year. The company is currently consulting with advisors to provide clearer guidance to shareholders, including whether information can be provided to allow shareholders to make a "Qualified Electing Fund" election regarding their shares. Additional guidance is expected to be available soon.
Note: A Passive Foreign Investment Company is a special classification under U.S. tax law concerning the tax treatment of U.S. investors holding shares in such foreign companies, requiring compliance with specific reporting rules based on shareholding.