The Japanese listed company Metaplanet holding Bitcoin may be classified as a PFIC by the United States.

On June 11, Simon Gerovich, CEO of the Japanese listed company Metaplanet, which adopts a Bitcoin reserve strategy, stated that Metaplanet is currently evaluating whether it will be classified as a Passive Foreign Investment Company (PFIC) by the U.S. Internal Revenue Service for its American shareholders.

According to the existing guidelines of the IRS, if 75% or more of the income in a tax year is passive income, or if 50% or more of the average assets held in that tax year produce passive income or are held to produce passive income, Metaplanet will be classified as a passive foreign investment company for that tax year. Although Metaplanet believes that the vast majority of the company’s goodwill can be classified as active assets, the IRS may disagree with this determination and is likely to classify Metaplanet as a passive foreign investment company in the 2025 tax year.

Currently, Metaplanet is communicating with advisors to provide clearer guidance for shareholders, including whether information can be provided to allow shareholders to make a “qualified electing fund” choice regarding their holdings. Additional guidance is expected to be provided in the near future. Note: Passive foreign investment companies are a special classification under U.S. tax law for non-U.S. companies, primarily involving tax treatment rules for U.S. investors holding shares in such companies, and compliance reporting must be ensured based on the shareholding situation.