FacultyFaculty/Author Profile
Christopher Ocasal

Christopher Ocasal


Washington, DC, USA

Chris Ocasal is a member of Ernst & Young LLP's International Tax Services practice, with nearly 20 years of international tax experience. He serves in the Financial Services Office and is based in Washington, D.C.

Chris regularly evaluates and opines on the status of public and private foreign corporations as PFICs. He assists companies in structuring their operations to avoid PFIC status and restructuring of PFICs. 

Chris has worked on several PFIC rulings, including PLR 200838003 and PLR 200943004, and has commented on PFIC reporting issues and has spearheaded changes to the Form 8621, including changes that no longer require a US partner to file a Form 8621 where the U.S. partnership has made a QEF election.

Chris has written several articles, and has presented at several conferences, on PFICs, including:

  • Christopher Ocasal & Charles Markham, Guest Commentary: Service Clarifies Characterization of Gain from the Sale of Look-Through Stock for PFIC Testing Purposes, 35 Tax Mgmt. Intl. J. 176 (2006).
  • Christopher Ocasal & Charles Markham, The PFIC Look-Through Rules: A New Level of Thinking, 35 Tax Mgmt. Intl. J 59 (2006).
  • Christopher Ocasal & Carol Tello, New PFIC Guidance Provided: But More Remains to be Done, 38 Tax Mgmt. Intl. J. 675 (2009).
  • Christopher Ocasal et al., The Proposed Notional Principal Contract Defnition Some U.S. International Tax Implications, 41 Tax Mgmnt. Intl. J. 387 (2012).
  • Chris is also the author to two BNA Management portfolios on the US taxation of notional principal contracts and the US international tax implications of insurance transactions, where he discusses at length the interaction of these areas and the PFIC regime.

Prior to joining Ernst & Young LLP, Chris was a partner at an international law firm and for another Big Four accounting firm's national tax services group. He was also an international tax lawyer with another major law firm in its New York and Washington tax practices.


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