Living in Switzerland as a US citizen –
The Challenges of Overlapping Rules
The United States is the only developed country in the world that taxes its citizens and green card holders based on citizenship, even when they live in a foreign country. Being an American in Switzerland therefore requires managing US financial and tax rules on top of the Swiss ones. To make matters more complicated, these rules are not always compatible, and yet, somehow, you need to make sure both systems co-exist with minimal conflict.
We can help you in the following areas:
- US investments: Not every brokerage firm can keep you as a client after you move to Switzerland. Additionally, US mutual funds cannot be purchased by non-US residents. We can help you transition your investments to a globally diversified, low-cost ETF (exchange-traded fund) portfolio that is compliant with US and Swiss regulations.
- US accounts: We can guide you on keeping or closing US bank accounts, credit cards and mortgages after ending US residency. We aim to minimize costs and will consider your FICO score.
- Swiss accounts: We can help you understand your Swiss banking options and open accounts at Swiss banks that are friendly to American citizens
- PFICs (Passive Foreign Investment Companies): The US tax code treats non-US registered mutual funds, ETFs and other pooled investments as PFICs. PFICs require complex reporting tax forms and are subject to punitive taxation. Generally speaking, Americans should avoid PFICs and continue to invest in US funds. However, Swiss advisors regularly recommend to Americans Swiss investments that are treated as PFICs. We can help you understand what investments are problematic while you are living in Switzerland. We can also help minimize your Swiss pension PFIC exposure, particularly in Vested Benefits Accounts (Compte de Libre Passage or Freizügigkeitskonto) and Pillar 3 pensions accounts, where PFIC risk is highest.
- Citizenship-based taxation: You will need to file US tax returns and potentially pay US income tax, in addition to Swiss taxes, while you live in Switzerland. We can help you avoid double taxation by using US and Swiss domestic tax provisions, tax treaty benefits and by taking advantage of disparities between the US and Swiss tax rules.
- Foreign account reporting: We can help you understand how to correctly report your US accounts in Switzerland and your Swiss accounts in the USA. This will help keep you in compliance and away from trouble and potential offshore reporting penalties with both the US and Swiss tax authorities.
- Swiss wealth tax: Switzerland does not tax capital gains on securities but imposes a tax on your worldwide wealth instead. This tax is levied at the cantonal and municipal level. Rates vary, and it is not creditable against US income tax. We understand how different American and Swiss assets are taxed, and can help you avoid paying more wealth tax than you need to.
- Social security: Under the terms of the Totalization Agreement for social security taxes between the USA and Switzerland, you may be able to continue to contribute into the US system during your first five years of Swiss residency. We can help you understand if this option is available, and decide if you benefit by claiming this provision. As you approach retirement, we can help you understand how to claim benefits under this treaty to maximize your combined US and Swiss social security benefits.
- Health insurance: Basic health insurance is mandatory in Switzerland. It is typically not provided by employers, but rather it is the individual’s responsibility to obtain and pay for it. We can educate you about the Swiss health insurance system and help you choose the right coverage for you and your family.
- Estate planning: Unlike the USA, Switzerland has forced heirship rules and does not have its own trust laws, although it may recognize US wills and trusts. We can help you review your US estate plan, determine if Swiss estate documents are necessary, and coordinate with US and/or Swiss attorneys licensed to draw up the relevant documents in the required jurisdictions.
- Other considerations: International moves are costly and complex. We can help you budget for them, manage your cashflow, manage foreign exchange rate risk, international money transfers, employee benefit choices, executive compensation and other financial relocation related considerations.
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