Xpat

Is Sanofi a PFIC?

SAN · Euronext Paris · U.S.: SNY · ISIN FR0000120578 · incorporated in France · Health care

PFIC-screened: company says not a PFIC (2024)

The company states it was not a PFIC for 2024 in its 20-F. Xpat's own estimate: passive assets about 5% of total assets at market value (test: 50%) (SEC XBRL, 2025-12-31). The test is rerun every year.

Checked 2026-11-15Xpat's reading · Xpat's reading of PFIC screen for individual stocks: Xpat screens by type of company: operating businesses pass, funds, investment trusts and cash-rich holding companies are excluded. The test is annual and only the company can confirm it, so a stock is PFIC-screened, not certified. Banks and insurers pass only through the active banking or insurance exception, so they are shown as screened with that caveat. Where a company has published a statement, the stock records its year and source. · Xpat's reading of PFIC check from company statements and financial statements: Passive assets are estimated as cash plus financial investments (Xpat counts all cash as passive, the long-standing IRS position). Total assets are taken at market value (market capitalisation at the balance-sheet date plus liabilities), the basis a publicly traded company may use, when the share count and price are known; otherwise at book value, which errs high. A company statement is read from its own clause, and a present-tense statement in the annual report for a year counts for that year. Passive income is estimated as finance income over revenue plus finance income. At or above a legal threshold the stock is excluded; from 60% of a threshold it is flagged as elevated. A company statement that it was not a PFIC, for a year at most two years before the tax year, outweighs the estimate; a statement that it was one excludes the stock. Banks and insurers are not estimated: they rely on the active banking and insurance exceptions. · 26 U.S.C. §1297 — passive foreign investment company (official) · 26 CFR §1.1297-1 — definition of a PFIC (income and asset tests) (official) · 26 CFR §1.1297-4 — qualifying insurance corporation (official)

What the company says

“Based on our financial statements and relevant market and shareholder data, we believe Sanofi was not a PFIC for US federal income tax purposes with respect to its 2024 taxable year.”

20-F filed 2026-02-17, statement for 2024 · Read the filing (SEC)

Xpat's estimate from the financial statements

Total assets (book value)EUR 126.8bn
Total assets at market value (market cap EUR 100.9bn + liabilities)EUR 156.0bn
Passive assets (cash and cash equivalents, other current financial assets)EUR 8.4bn
Passive share of assets (market value; PFIC at 50%)5%
Finance income (interest, dividends, investment gains)EUR 394m

SEC XBRL figures for the year ended 2025-12-31 · Source filing. All cash counts as passive and total assets are taken at market value when the share price is known, else at book value, so the estimate errs high.

What it means for a U.S. citizen or green-card holder

No PFIC filing for this holding while it stays a non-PFIC: dividends are reported like any foreign dividend (with a foreign tax credit) and gains as capital gains. Foreign accounts that hold it still count for FBAR and Form 8938.

Company type: Operating company. Evidence gathered 2026-11-15. Educational tool, not tax advice: PFIC status is decided each year on figures only the company has.

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