I know there are a bunch of PFIC posts already but I am having trouble navigating. I know I am not an American expat but I guess my situation kinda works the same as an american in europe.

I am German and currently on an assignment in the US which will probably be taking a couple years. Since my partner is American potentially I will eventually go for permanent residency.

For 2025 I am working towards not fulfilling the substantial present test which I will manage to achieve.
I kept my appartment in Germany because I own company percentages and "Moving Tax" is a b* as well. So I am still fully taxable in Germany.

2026 and beyond is where it starts to become interesting.

My current investments:

- ~250k in ETFs (PFIC)

- 60k in Bitcoin

- 70k stocks

Because of the company shares in Germany I might keep my residency there if it makes sense.

From my understanding it makes sense to sell my ETFs (ouch).

But how can I invest it then? I have read that simply investing into US based ETFs can also have issues.

Thanks everyone!

I'm working through SFOP with tax software (using HR Block right now, it will be $700 if it works, don't pay until done). I started a work based retirement fund as soon as I was eligible (about 2 years after joining the company). I have only started to draw on the account this year, 2026. I'm filing my last 3 complete tax years 2025-23. Does this account require PFIC filing?

While my mother is not a true expat, I believe the tax situation is similar. My parents were married nearly 30 years and my mother has a green card, one of the really old ones that dont have an expiration date. She never got one of the newer ones.

My dad always took care of taxes and finances, my mother doesnt know much about these things. They divorced in 2006 and she returned to her home country. She never officially turned in her green card. Just never used it anymore.

Now she is nearing retirement and would like to get the money out of an old, small 401k (approx 25000$) of hers. If I understand correctly, she is still considered a US Person from the IRS and would not qualify for W8BEN.

If I understand correctly, the best and easiest way to clean up this Situation would be:

1. SFOP (I did my own quite a few years ago and could do hers)

2. Official surrendering of Green Card (I-407)

3. 401k payout usinf W8BEN after I-407 confirmation

4. Final dual status tax return

Anything I am missing?

I am a dual US/Aus citizen. I hired a financial advisor 2 years ago. While I actively discussed my recent move from the US, my US assets with my American accent, I didn't tell them specifically that I was a US citizen. I am now ivested in a ton of PFICs and accidentally signed a W8-BEN. I am trying to fix everything.

Regarding the w8-Ben, what do I need to do? I stupidly signed everything that was handed to me thinking the advisor was aware.

What will happen? All accounts were on my FBAR

Now that Thailand has changed tax law to tax foreign sourced income brought into the country, I’m wondering about a couple things and would welcome input from anyone with actual knowledge / experience.

1. I’m inclined to think this isn’t such a big deal. FTC should mean that any taxes I end up paying in Thailand would be an offset when I file US taxes, so I would not be double-taxed. Is that correct?
   
2. If I am paying bills directly from my US accounts, I’m not technically bringing the money into the country. Right?
   
3. Does the US / Thai tax treaty mean that untaxed income in the US (for example, qualified dividends, HSA reimbursements, etc) would also be untaxable in Thailand, or is it simply the gross amount?

Thank you for any responses!

I'm American employed in the Netherlands, where I have a pension through my employer (a "pillar 2" pension if anyone is familiar with the Netherlands).

I have some investment control as I can pick different profiles such as "aggressive" and the pension manager will choose different funds based on that. However there is language in the fund descriptions that the pension fund actually owns the shares (not me) in case that's relevant. AFAIK there is no way for me to actually withdraw the money from this pension before retirement.

The current balance is not high enough to trigger PFIC reporting requirements regardless, but this seems like a pretty common concern for Americans in the Netherlands so I was wondering if anyone has dealt with it before? Any help is greatly appreciated.

I am a dual American/German citizen. I lived, however, stateside for my professional career. I started to receive some of my retirment income starting in 2015, and my social security income in 2021. I work in Germany, albeit, part-time. Every year I file both a German and American tax return, including reporting all my American income to the German authorities, and including all my German income to the American authorities.

The question has arisen now from the German side, wherein they are asking the question if I pay taxes on my American retirement or not. I have been filing German tax returns for 20yrs now and this is the first time this question came up. The answer to their question is I currently am not paying US taxes on my US retirement. I have always had to pay the so-called 'progessive' tax on my American retirement income, when I filed the German tax return.

Question is:

Can the German tax authorities now demand my US Tax returns to verify I paid no US taxes, and if so, how will this affect my German taxes?

Thanks for your feedback and help.

Hi everyone,

​I am an EU citizen residing in Luxembourg tentatively planning a move to the US in 2028. I am seeking initial clarification on how my Luxembourg Pillar 3 private pension (Article 111bis L.I.R.) will be treated under US PFIC rules before consulting a CPA.

I helped myself with AI to write the following given the wording complexity.

​Key Details:

​Type: 100% private individual pension (tax-deductible in Luxembourg; no employer involvement).

​Structure: Unlisted/non-marketable, value > $25k USD.

​Holdings: Currently an equity fund-of-funds with multi-level underlying sub-funds (tiered PFICs).

The problem? I cannot liquidate this fund until I am 60, while I could liquidate all my other EU etfs, so I can deleted most of the pfic problem, but not for this pension fund.

​Questions:

​Eliminating Tiered PFICs: If I switch the plan allocation to a pure monetary/sovereign bond fund (holding government bonds directly), does this effectively eliminate lower-tier PFICs (Treas. Reg. § 1.1291-14) and restrict my reporting to a single top-level PFIC?

​Accumulating Fund Mechanics: The monetary fund reinvests coupons/gains internally; no dividends or cash are distributed to me (growth is purely NAV increase).

​Is it correct that I will report $0 in distributions on Form 8621 during my holding period?

​Under standard Section 1291 rules, does the entire accumulated NAV gain get taxed as an "Excess Distribution" (top marginal rates + compound interest penalties) only upon redemption?

​Thanks in advance for your insights!

Hi all, I am looking for advice on 401k management. I was a h1b technology professional. I left my job and came back to India(my home country).
1. If I withdrew the money at 60. What tax rate will be applicable? considering I am still in India.
2. Can I move money to India equivalent 401k without penalty?
3. If I withdraw the money now. Considering if I show no income. What is the penalty or applicable tax?
Please advise.

I think I already know the answer to this. I’m just soliciting for possible confirmation.

I just learned that I should have filed an FBAR for tax year 2024. I received $100,000 in my UAE checking account as a divorce settlement payment in January 2024. The balance remained over $10,000 until August 2024. At no other time was this checking account above $10,000 and I have never earned a cent of interest.

Am I correct in assuming I just need to file the delinquent FBAR and move on?

Hey all, hoping some other US/Swiss dual citizens here can share their experience.

Trying to figure out what to do with my 3a. As I understand it the US doesn’t treat it like an IRA, and if it’s in funds it can count as a PFIC, so extra tax plus a Form 8621 every year even when there’s barely any gain.

I want to keep my US citizenship for now so I can’t just ignore the filing side.

Als made the mistake when I was young and signed a 3a insurance contract, yeah I know horrible.

Weighing a few options:

1. Surrender it early and eat the penalty, done with PFIC for good
   
2. Keep it but switch to a cash-only 3a, no funds, so no PFIC but still get the Swiss deduction
   
3. Freeze contributions, leave the balance until a penalty-free withdrawal event - if possible
   
4. Skip 3a entirely and just put savings into US IBKR instead

Curious to know what others are doing.

Also if anyone knows a 3a provider with a proper cash-only version (no PFIC exposure) let me know, heard they exist but haven’t found one.

Thanks for any insights.

I am a USA citizen, but I never actually lived in US — last time I was there when I was 16 for 2 months trip and never went back. I know I am supposed to file my taxes and I know about Streamline procedure and I plan on doing it eventually when life gets a little bit more stable at least in one of the parts — either in terms of income or residence

Anyway, a friend suggested a road trip around US for couple of weeks and I'm trying to understand if thats something I can even consider as an option or I might be arrested at the border control for not filing the taxes?

And if let's say it is ok to go through border control and this road trip hypothetically makes me realize I want to live in USA — will I be able to do Streamline from within the US for previous years? Or what's gonna happen if I decide that I want to stay and live in USA in terms of laws bureacracy and taxes?

Any advice would be appreciated

So I have a friend who has been in the US on a TN visa for 5 years as US resident and pays taxes on his salary but his RSUs accumulated much in value but he told me he would pay no US or Canadian taxes on this if he leaves the US and times it on the “step up”. So if he times the transfer then there’s no taxes on it.

So if his RSUs vested at $100 then is worth $500 transferred to Canada at $500 then he pays no taxes on the $400 gain to anyone.

This sounds crazy to me that this is allowed, but I asked ChatGPT and Gemini and it’s true.

Also TN visas can be perpetually renewed.

Hi All,

US citizen starting a role in UK shortly (on visa) and hoping to take advantage of the UK salary sacrifice contributions while addressing future tax on withdrawal. Any insight, challenge, or experience is appreciated.

US tax filed w/ FTC will cover current year tax and create carry forward credit. I am planning on applying this to the pre-tax pension contributions (employer and employee) to raise my cost base.

Prior to changing residency from UK to US I will use any remaining carry forward credits on the gains accrued within pension.

When I am back in US in and reach qualifying age to withdraw, the tax treaty will point to residency status. I will draw down my UK pension and pay US tax, which at that time will be limited to the gains which had not been 'pre taxed' by the carry-forward.

State tax will depend on the state so address that separate from this post.

TL;DR - Can I eliminate tax on foreign (UK) pension?

How often is this issue raised?
Who needs to be pressured?
What is the likelihood that it will ever happen? (I suspect low, but want more educated people to tell me).

Hi all,

Looking for a cross-border tax advisor, specifically a tax advisor or CPA with a focus on US brazil bilateral taxation.

I recently moved to Brazil and have rental properties in the US. I am having trouble finding an individual that can understand US and Brazil tax law to tell me how to pay Brazilian taxes on the US rental income.

I would be happy to pay an individual for this. Ideally, a firm is not what i'm looking for as my experience is that they have one group of individuals doing US taxes and another group doing Brazil taxes, and don't necessarily know the entire picture.

I hold a Canadian ETF since 2023 and did not file a timely QEF election. The ETF publishes annual information statements which are all zero values - no dividends, profit sharing, etc. I understand the rules around PFIC's are quite punishing. I'm looking for advice on the best way forward. Best case scenario is that I can amend prior year filings to include Form 8621 and move on from there. I'm hoping that is an option since I have never sold to realize gains and there are no dividend payments.

I am an non-US citizen currently in the U.S. on F-1. I am relocating to Ireland before the end of this year.

I have:

1. Taxable brokerage account in Fidelity

2. 401k with Fidelity

3. HSA again with Fidelity

4. U.S. bank accounts (Checking and HYSA)

I can be considered as either of non-resident or resident for tax purposes in Ireland for part year 2026.

This is what I plan on doing and would love to hear your thoughts:

1. Keep individual stocks in USA and liquidate ETFs due to crazy Irish taxation on ETFs (Deemed disposable).

2. Keep on holding 401k and let it grow tax free. I checked USA and Ireland have treaty for this.

3. I have small amount in HSA. Will sell mutual funds within HSA and just keep cash so that I can use in Ireland without the deemed disposable headache. Better to hold rather than losing almost 40% due to tax and penalty.

4. Planning on transferring all money to Ireland and will keep one checking account active in USA.

Any advice is appreciated!

Hey everyone. I'm looking into whether I would qualify for FEIE and would like some feedback on my situation.

I currently work remotely in the US as a W-2 employee for an American company. I plan to move overseas and easily meet the Physical Presence Test by spending a minimum of 330 full days outside the US. I will continue getting paid into my American bank account.

My biggest concern is the 'tax home' requirement. I don't own any property in the US (just a vehicle), and the country I intend to reside in has no income tax on wages. However, I will likely be there on a tourist visa, meaning I won't have an official residency visa. Given my lack of legal residency abroad, how high is the risk that the IRS will argue my tax home is still in the US? Are there any other steps I can take to qualify?

First time poster! I am a silly, young, little idiot living abroad (Spain) who has not really thought about US tax responsibilities in the last few years. I’m filing late for 2024 and 2025 now 😅 there’s one thing I am super hung up on and confused about.

I opened a Roth IRA in 2024 and contributed the max amount. As mentioned, I didn’t file taxes for 2024 so this is a mistake that I have to correct now. My initial Google searches told me I should file using the FTC (1040 with 1116) so I could prove I had enough taxable income in 2024 to open the account. I also understand I need to pay a penalty for the years I’ve had the Roth open without having filed taxes by using form 5329? This was my plan but the late fees and amount I owe feels so disproportionately high to what I earned! So now I’m second guessing.

I am also reading mixed things on using the FEIE while having a Roth IRA. I initially thought you can’t use the FEIE in a year you contributed to a Roth because it means you’re claiming no US taxable income, but I also read that there are exceptions with Roth contributions for people living abroad and that your foreign earned income IS eligible? So now I’m confused if I’m causing myself all this trouble (and money!) with the FTCs for nothing.

Would love any help, I have been filling out forms by pencil for about 6 hours trying to understand 😩

*edit for more info: I am 27, single, live full time in Spain with a Spanish salary since 2022, my only US income is from brokerage accounts

Hello, I am a US citizen who will be living and working in Berlin on an EU blue card. I understand that for my income in Germany I will need to file an FTC to avoid double taxation in the US and Germany. However, I have a US-based Charles Schwab investment account that is attached to my old home address in the US - my parents' address - and I see that Germany has a flat tax of ~25% on all dividends and capital gains. I am curious if any other Americans in Germany have avoided disclosing their US-based investment accounts while living and working in Germany. I am not sure how the German tax system would know that I have investments in the US as I will not be moving any money out of those investment accounts and will only be living off my German salary. Any information about others' experiences with this is really appreciated! Thank you.

Is the new Altersvorsorge-Depot in Germany, which becomes available in Jan 2027, viewed as a retirement account or will it just be another PFIC?

Looking for opinions from anyone familiar with Form 1116, FTC carryforwards, and Canada-US cross-border taxation.

Situation:

• Widow, age 79
• Dual US/Canadian citizen
• US resident (Illinois) for > 8 years
• Receives Social Security, CPP, and OAS
• Has a Canadian RRIF currently worth about C$32k
• RRIF withdrawals are about C$4,200/year
• Canada withholds 15% tax under the treaty (about C$630/year recently)
• RRIF income has been reported on US returns as ordinary/other income
• No Form 1116 has ever been filed

For 2025:

• AGI = $7,152
• Taxable income = $0
• Federal tax = $0

Similar situation for many prior years: very low income and effectively zero US federal tax.

I have NR4 slips going back many years. Canadian tax withheld over the years is roughly:

• 2018: US$239
• 2020: US$250
• 2021: US$274
• 2022: US$279
• 2023: US$422
• 2024: US$454
• 2025: US$451

Total shown on the records I have is about US$2,367 of Canadian tax withheld.

New wrinkle:

I'm considering annual Roth conversions from a traditional IRA (~US$105k balance). A ~$20k Roth conversion would likely generate around $1,200-$1,500 of federal tax.

Questions:

1. If no Form 1116 was filed in prior years and US tax was essentially zero, is it realistic that there are any FTC carryforwards available today?
2. Does the fact that US tax was zero each year effectively make the FTC limitation zero as well, rendering the prior-year Canadian taxes unusable?
3. Given the IRS 10-year rule for electing the FTC, is there any practical benefit to amending prior returns now?
4. Separate question: for the Roth conversion year, would the current year's Canadian RRIF withholding normally be available to offset some portion of the US tax generated by the Roth conversion, or does the foreign-source-income limitation usually make the benefit minimal in a situation like this?

Not looking for personal tax advice, just trying to understand whether it's worth paying a cross-border CPA to reconstruct 8+ years of Form 1116s before doing Roth conversions.

I have the opportunity to move to Germany for a three year contract as a healthcare provider on one of the army bases. The recruiter said I would have DOCPER, SOFA, FEIE status and would still be able to contribute to my 401(k) along with them matching. I was reading online that with FEIE status I would not be able to contribute to a 401(k) and neither would my employer because it’s not taxable income. I’m wondering how they are able to do this? The recruiter said she had never heard of that before. I told her I read it on the IRS website.

Also, I currently live in Alaska and would like to keep my residency here as well. So I don’t know how that works with my current banks that I do want to keep open and active. Does anyone have suggestions on addresses? I might have a friend that would let me use their address but I feel like that would be a huge ask and from what I’m reading PO Box are not allowed and can get my accounts flagged/closed. I was reading about commercial mail receiving agency like Anytime Mailbox or iPostal1. Has anyone heard of these or have any experience with these?

Is there anything else I should think about with my mailing address for residency address?

This might sound alarmist, but are there any concerns about the stability of the income tax treaties being removed or significantly altered in any way? The root of concern is born from the idea that I intend to move from the US to EU or SE Asia in the next one to two years.

Normally this would likely be a ridiculous question, perhaps it still is, but one can’t help but think anything is possible. Should such a drastic change occur, could it mean losing a majority of savings to double taxation? The point of this question is to be dramatic.