I just looked at the US tax information in the circular. An important distinction in the tax rules is whether the stock was considered a PFIC (Passive Foreign Investment Company) during the shareholder's ownership period, or not. I quote from p. 99:

"ECU believes, and the following discussion assumes, that it may be and may have been a PFIC in one or more years since its formation."

I have run into the PFIC issue with Central Fund of Canada in the past. IRS Form 8621 is no fun at all to deal with.

Does anyone know if, in fact, ECU qualified as a PFIC at any time? If so, during what years?

Thanks much in advance for any info you can provide.