Living in the USA with Swiss Ties –
Financial Planning Implications
The United States government does not provide a broad a safety net as the Swiss government does for its residents. As a result, US residents are used to taking a more active role in managing risk and building wealth to support themselves in retirement. This can be intimidating for Swiss nationals moving to the USA for the first time, and it requires a shift in mindset for Americans returning to the USA after decades living abroad.
We can help you manage your international relocation and coordinate your US and Swiss finances in an efficient manner, whether you are moving to the USA for the first time and need to learn your new environment, you are a Swiss family that has been living in the USA for a number of years, or are an American family returning home after years living in Switzerland.
We can help you manage your:
- Pre-immigration tax planning: Like Switzerland, the USA taxes its residents on their worldwide income. Unlike Switzerland, the United States doesn’t have a wealth tax, but it taxes capital gains on financial investments even if the appreciation of the investment happened before the owner moved to the USA. We can help develop a plan to tax efficiently step-up your cost basis on those assets prior to becoming a US tax resident, resulting in potentially significant tax savings.
- PFICs: The US taxes non-US mutual funds, Exchange Traded Funds (ETFs), and other pooled investments that are not US registered as Passive Foreign Investment Companies (PFICs). PFICs require complex tax reporting and are subject to punitive taxation. We can help you restructure your Swiss investments, including by making favorable US tax elections, to reduce the tax burden on those investments without negatively impacting your investment returns.
- Bank accounts: Some Swiss banks increase their clients’ account fees or force them to close their accounts after giving up Swiss residency. We can help you evaluate your options and structure your bank accounts and deposits to minimize disruptions, unnecessary costs, and risks.
- Pension distributions: US tax laws do not recognize Swiss Pillars 2 and Pillars 3 as qualified retirement accounts. When moving to the USA for the first time, capital distributions of Pillars 2 and 3 are fully taxed in the USA as income if taken after becoming a US tax resident. We can help you plan your US tax residency start date at the federal and state level, to reduce or eliminate these taxes. Rolling over a Pillar 3 account or rolling over your Pillar 2 to a Vested Benefits Account can also have income tax and PFIC consequences that we can help you understand, plan for and minimize.
- Reporting requirements: US tax residents are required to report their foreign financial assets in their US income tax returns and FBAR Form FinCEN 114 every year. These requirements apply to Swiss bank accounts, Swiss pensions and investment accounts, ownership of Swiss corporations and partnerships, real estate, certain insurance products, etc. Ownership of at least 10% of a non-US company such as a SA or AG, Sarl or GmbH, can trigger additional reporting requirements with different levels of complexity. We can help you understand the requirements that apply to your situation, avoid penalties and remain in full compliance.
- Tax treaties: There are three tax treaties between the USA and Switzerland: for income taxes, for social security taxes, known as the Totalization Agreement, and for estate taxes. We can help you navigate the treaties and claim any benefits that are relevant to your situation.
- Insurance: Coverage for disability and life insurance is not automatic or mandated by US law. Unlike in Switzerland, employers in the US generally provide very limited coverage and it is up to the individual employee to obtain this coverage We can help you select and obtain the right level of insurance coverage based on your personal circumstances and needs.
- Estate planning: Unlike Switzerland, there are no forced heirship rules in the USA. We can help you understand the estate implications of becoming US domiciled, and work with estate attorneys to put together an estate plan that addresses your needs and takes into account your US and Swiss assets.
- Other considerations: international moves are costly and complex. We can help you budget for and manage those expenses, manage foreign exchange rate risk, make international money transfers, select the most appropriate employee benefits, understand your executive compensation, and open and manage US investment accounts
If you are a US citizen relocating back to the USA from Switzerland or are Swiss but have been living in the USA for a while, you may already be familiar with some of these issues. Some considerations, particularly as they related to the taxation of Swiss pension distributions and foreign investment funds, change once you become a US tax resident. We can help you evaluate your options and make the choices that provide the best return for you, based on your personal situation and goals.
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