The Expat Sage Podcast

The Expat Sage
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Moving, Working, and Investing for Americans Abroad.Pre-relocation planning advice and investment strategies for American citizens moving abroad.Discover expert insights and comprehensive strategies for expats on investing in a dual taxation world, managing finances, and planning for retirement.

  1. 2D AGO

    PFIC Rules, Real Risks, Smart Moves

    A simple foreign fund should not blow up a decade of savings—yet for U.S. citizens abroad, the PFIC regime can turn a plain ETF into a financial trap. We pull back the curtain on how ordinary investments meet an extraordinary tax system, why the default rules punish long holding periods, and how to rebuild a portfolio that won’t collapse under Form 8621 and daily compounded interest. We start with the origin story: PFIC rules were crafted to shut down offshore shelters in 1986. The intent targeted billionaires, but the design is universal—so a teacher in London with a tiny slice of a local fund gets treated like a tax haven operator. We break down the 75% income test and 50% asset test, explain why most non‑U.S. pooled funds fail, and reveal the “time travel” math behind Section 1291. Selling a PFIC converts your entire gain into an excess distribution, spreads it across prior years at top ordinary rates, and layers on underpayment interest. The result can be a 57%–67% effective tax on a $100,000 gain, with losses offering little relief. Then we tackle the catch‑22. European PRIPs rules require a KID, but U.S. ETF issuers can’t provide it without clashing with SEC restrictions, blocking expats from the cleanest solution. Local wrappers like the UK ISA and Canadian TFSA don’t help under U.S. law, and accumulation share classes create phantom income with no cash to pay tax. We share practical fixes: when a QEF election is possible (and which providers issue statements), how a mark‑to‑market purge stops the interest time bomb, and why individual operating company stocks are a clean bypass. For UK listeners, we spotlight the sweet spot—U.S.-domiciled ETFs that also carry UK Reporting Fund status—plus the brokerage routes that make access possible. If you’re already holding a toxic portfolio, we lay out triage: shut off dividend reinvestment, harvest losses to simplify reporting, and evaluate a purge to reset the clock. The big takeaway is simple but urgent: structure determines outcome. Get the vehicles and elections right, and you keep more of your returns; get them wrong, and compounding belongs to the IRS. If this helped, follow the show, share with a fellow expat, and leave a review so more people can sidestep the PFIC trap. More info at Investing Abroad for U.S. Citizens and Resident Aliens. If you have questions, contact us.  Moving, Working, and Investing for Americans Abroad

    17 min

  2. JAN 16

    How UK Reforms And U.S. OBBBA Reshape Every Financial Move For Americans In Britain

    Finance rarely flips overnight, but 2026 comes close. Two permanent shifts collide: the UK ends the non‑dom era, and the U.S. OBBA cements the 2017 tax architecture, forcing Americans in Britain to rethink every choice around income, investments, pensions, and estate planning. We unpack why the UK’s new foreign income and gains relief can quietly increase your IRS bill, how the temporary repatriation facility at 12% becomes a tool for deliberate credit harvesting, and where timing mismatches turn smart moves into double tax. We take you inside the clash over capital gains rebasing, showing how the UK’s 2017 step‑up collides with the IRS’s original‑cost basis and leaves you with partial credits and a residual check to write. Then we get tactical: why the foreign tax credit method typically beats the FEIE when UK rates exceed U.S. rates, how excess credits become a strategic asset, and where state domicile rules in places like California and New York can trigger uncredited tax on worldwide income long after you’ve moved to London. Investors get a clear map of the twin minefields: U.S. PFIC penalties on non‑U.S. funds and the UK’s offshore income gains rules that tax non‑reporting funds at income rates. The solution is narrow but workable: U.S.‑domiciled ETFs with HMRC reporting fund status—the true “gold list.” We also decode the hardest retirement conflicts: the UK’s tax‑free pension lump sum that the U.S. taxes in full, ISAs that are tax‑free in the UK but taxable in the U.S., and the SIPP as one of the few bilateral safe harbors. Finally, we tackle the UK’s new 10‑year inheritance tax tail and the lifeline offered by the 1979 U.S.‑UK estate tax treaty, where proving U.S. treaty domicile can protect non‑UK assets. By the end, you’ll have a practical checklist—portfolio audit, LLC elections or distribution timing, and a decision on TRF credit harvesting—plus a new mindset: document your center of vital interests and plan actively with the treaty in hand. If this helped, follow the show, share it with a fellow expat, and leave a quick review so more people can find it. For an in-depth look, read Investing for US Citizens in the UK: Cross-Border Taxation 2026.  If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    13 min

  3. JAN 9

    The UK Rewrote Tax For Newcomers, And Your First Four Years Could Define Your Financial Future

    The UK recently rewired tax for global movers, and the clock starts the day you land. We unpack the Foreign Income and Gains regime, which replaces the non-dom concept with a hard four-year window during which foreign income and gains are exempt—no remittance gymnastics, no clean capital spreadsheets, and no offshore contortions. If you’ve been a non-UK resident for 10 straight tax years and arrive from April 2025, you can earn abroad and bring funds into the UK tax-free during your first four tax years, trading personal allowances for sweeping simplicity and real money. We go step by step through the strategies that matter when seconds count. New arrivals can harvest gains on long-held foreign assets and immediately repurchase to step up basis, permanently pushing old appreciation outside the UK tax net before year five. Existing non-doms get a two-year bridge via the Temporary Repatriation Facility: a flat 12% to clean up mixed funds that once carried a 45% risk. And for U.S. citizens, there’s a standout move—Roth IRA conversions during the four-year window. By classifying the conversion as foreign pension income, the UK ignores it, while surplus U.S. foreign tax credits from your UK-taxed salary can wipe the U.S. bill, creating near-zero global tax conversions and locking in treaty-protected, tax-free growth. Then we tackle the hard turn after the sprint. HMRC is shutting down the old lump-sum arbitrage on U.S. pensions, pushing you toward cleaner periodic withdrawals. More critically, inheritance tax flips from subjective domicile to a 10-year residence test, with a 40% charge on worldwide assets and a 10-year exit tail. The 1978 US‑UK Estate and Gift Tax Treaty may override the UK’s domestic reach if you re-establish U.S. domicile, but it demands careful evidence and timing. Our takeaway: plan front-loaded, act inside four years, and reassess before year ten. If this regime is a golden window with a trapdoor, your best defense is sequencing. Subscribe, share with a friend who’s UK-bound, and tell us the one move you’re prioritizing in year one. More information about investing as a US citizen resident in the UK here. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    14 min

  4. JAN 2

    How Sticky States, like California, New York and Virginia, Keep Tax Claims After You Move Abroad

    Planning a move abroad and feeling good about the federal side? The real fight may be back home. We unpack how California, New York, and Virginia use domicile and statutory residency to claim your worldwide income long after you’ve crossed an ocean—and why keeping a “just-in-case” home can quietly unravel your whole plan. We start by demystifying the two tests that decide your fate: domicile, the intent-based anchor that sticks until you clearly replace it, and statutory residency, the cold math of days and access. From there, we dive into California’s closest connection analysis where empty houses, family location, club memberships, licenses, and even ATM swipes during visits can outweigh your signed statements. We also break down the booby traps in California’s 546-day safe harbor—the 45-day limit and the $200,000 intangible income cap that’s lethal for RSU-heavy compensation—plus the lingering bite of 1031 exchanges tracked by Form 3840. Then we head to New York, where auditors deploy the “teddy bear test” to see where your most cherished items live. If the heirlooms and insured art never left Manhattan, they argue your heart didn’t either. We explain how to pass that test with physical moves and dated bills of lading, and how to avoid the statutory residency snare of a permanent place of abode and 183-day counts. Timing matters here: selling before November 1 can break the “substantially all year” element and save you from a global tax bill. Finally, we examine Virginia’s presumption of continuity, where small choices carry huge weight. Keep a Virginia driver’s license or vote after “moving,” and you’ve essentially declared residency. We lay out a clean break blueprint: convert your home into a mere asset with a long-term lease to an unrelated tenant, avoid short-term rentals, execute a ruthless pre-departure purge, consider the Florida shuffle to create a no-tax fallback, build a robust paper trail abroad, and count your days with discipline. If you’re serious about a tax-safe international move, this guide gives you a practical playbook and the mindset to match. Subscribe, share with someone planning a move, and leave a review with your biggest lingering question—we’ll tackle it in a future episode. Read other key considerations for Americans Moving Abroad here. Moving, Working, and Investing for Americans Abroad

    16 min

  5. 12/26/2025

    From Golden Visas To Tax Traps: Portugal, Italy, Spain Compared

    The ground has shifted under European residency, and the shortcuts are gone. We pull apart the new reality for Americans eyeing Portugal, Italy, and Spain, showing where mobility still works, where it doesn’t, and why structure now matters more than spend. You’ll hear a clear framework for the three pathways—investment, passive income, and active talent—and how each one shapes your rights, your tax exposure, and even your employer’s risk. We break down Portugal’s pivot to investment funds and cultural donations, the GPAC bottlenecks that slow approvals, and the proposed 10‑year citizenship change that could erase a key advantage. Then we contrast Italy’s investor visa—zero minimum stay and clean decoupling from tax residency—making it a strong plan B for capital‑rich applicants. For retirees, we compare Portugal’s accessible D7 with its 12‑month lease hurdle against Italy’s stricter ERV, highlighting the “LLC trap” that turns passive income into disqualifying active work and the Tar Lazio ruling that allows aggregated household income. For digital nomads, we explain why Spain leads on volume: the DNV paired with the Beckham Law’s 24 percent flat rate for employees, not freelancers. We detail why going autonomous in Spain often kills the math, how Portugal’s D8 lost its shine after NHR, and what Italy’s current stance means as it weighs a 2026 tax bonus that could reshape the competition. Threaded through it all is the compliance risk of permanent establishment: how a home office or contracting authority can trigger European corporate taxes for a U.S. employer, and how to use an employer of record or contractor setup to control exposure. If you’re choosing a path, we map optimal routes by profile: Italy’s investor visa for a decoupled plan B, Portugal’s D7 for a passive, active lifestyle with care, and Spain’s DNV for employees who can capture the Beckham advantage. Subscribe, share this with a friend planning a move, and leave a review telling us which country you’re betting on next. More in-depth country-specific publications here. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    13 min

  6. 12/19/2025

    The Expats’ Playbook For Moving To Spain

    Thinking about trading gray skies for Mediterranean light? Before you pack your bags for Spain, we unpack the exact moves that protect your portfolio, your cash flow, and your peace of mind. Spain taxes by residency, the U.S. taxes by citizenship, and the two systems collide in ways that can either cost you dearly or, with the right structure, work in your favor. We start with the moment Spain claims you: the 183‑day test, center of economic interests, and the family presumption. From there, we navigate the “saving clause” in the U.S.–Spain tax treaty and explain why the Foreign Tax Credit often zeros out your U.S. federal bill but never your filing obligations. We also spotlight the sticky states—California, New York, Virginia—and the steps needed to truly sever state tax residency. Then we dive into the game‑changer: the Beckham Law. You will learn who qualifies, the six‑year window, the flat 24% on Spanish employment income, and the powerful exemptions for foreign income and non‑Spanish assets from wealth tax and the solidarity levy. Investors face a unique squeeze between Europe’s PRIPS rules and the U.S. PFIC regime. We break down two viable solutions: the options assignment strategy using a broker like Interactive Brokers, and direct indexing to mirror an index without touching PFIC‑land. Retirement savers get a reality check on Roth IRAs—Spain taxes the growth and counts the balance for wealth tax—plus practical guidance on traditional 401(k) and IRA distributions and how Social Security is treated under exemption with progression. We also compare regional wealth tax policies—Madrid and Andalusia’s relief versus Catalonia and Valencia’s higher rates—so your choice of city aligns with your balance sheet, not just your lifestyle. To close, we flag the stealth risks that blow up credits: phantom currency gains when the dollar moves against your euro assets, and mismatched cost‑basis rules that force different gains in each country. You will leave with a crisp five‑point 2025 checklist: secure Beckham within six months, avoid PFICs with smart structures, cut state ties completely, pause Roth funding and plan for Spanish taxation, and choose the right region for wealth tax. Subscribe, share this with a friend planning a move, and leave a review with your top question for a future deep dive. For detailed information, read the book Investing for US Citizens in Spain, a Cross-Border Wealth Management and Investment Strategy. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    16 min

  7. 12/12/2025

    The U.S.–Swiss Financial Double Lock Explained

    It’s not a glitch. It’s the system. When U.S. citizenship-based taxation meets Switzerland’s residence-based rules, the result is a financial double lock that touches every account, fund, pension, and estate plan. We unpack how FATCA hardened bank compliance, why neo-banks shut out U.S. clients, and how the shift to a Model IGA will make transparency automatic and unavoidable. Then we map the roadblocks that turn simple investing into a maze: PFIC rules that punish European funds, and Swiss KID requirements that block U.S.-domiciled ETFs from retail sale. We get practical about solutions, not just problems. Learn how Interactive Brokers enables execution-only access to U.S. ETFs, when qualifying as a professional client lifts the KID barrier, and where the options assignment method can lawfully place shares in your account without a direct sale. We weigh the costs and risks of direct indexing with individual stocks, showing how to stay PFIC-free without surrendering diversification. Along the way, we explain the hidden traps in the Swiss three-pillar system—phantom income on Pillar 2 contributions and PFIC landmines inside many Pillar 3A products—even after the trust-reporting relief of 2020. Finally, we zoom out to the lifetime tax picture: limited foreign tax credits, non-creditable Swiss wealth tax, and the harsh contrast on capital gains where Swiss neighbors pay zero while Americans owe U.S. tax with no offset. We close with the estate tax sting that many expats underestimate. Our playbook is clear: accept compliant banking costs, stick to U.S.-domiciled ETFs via execution-only routes or build with individual stocks, keep Pillar 3A in cash or guarantees. Subscribe, share this with a friend in Switzerland, and tell us: which part of the double lock hits you hardest? For detailed information read the book Investing from Switzerland, a Comprehensive Analysis of Cross-Border Wealth Management for U.S. Persons Domiciled in Switzerland. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    15 min

  8. 12/05/2025

    Investing Minefield for Americans in Europe

    We map the collision between U.S. citizenship‑based taxation and European investing, then give a clear, four‑pillar plan to build wealth abroad without triggering PFIC penalties or losing key tax benefits. The goal is simple: avoid the traps, use treaty shelters, and keep your strategy compliant. • Why citizenship‑based taxation conflicts with European “tax‑free” investing • How FBAR and FATCA create global visibility and enforcement • Why EU funds and UCITS ETFs trigger PFIC treatment • What PFIC taxation and interest charges do to returns • The EU‑US blockade on funds and how to navigate it • Pillar 1: choosing a compliant global brokerage with 1099s • Pillar 2: using Foreign Tax Credit instead of FEIE to keep IRA and ACTC • Pillar 3: leveraging treaty‑protected pensions like UK SIPP and French PER • Pillar 4: using EPC status or individual securities to avoid PFIC and PRIIPs • Red flags in Germany around private pension schemes and foreign trusts • The need for cross‑border expertise and when to change advisors If your current financial advisor or your tax preparer doesn't immediately understand the strategic difference between using the foreign earned income exclusion and the foreign tax credit, and its direct impact on your ability to fund a US retirement account, then you need to find a specialist advisor right now. See the book Expat Tax Guide: 101 for U.S. Citizens Investing in Europe. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    13 min
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About

Moving, Working, and Investing for Americans Abroad.Pre-relocation planning advice and investment strategies for American citizens moving abroad.Discover expert insights and comprehensive strategies for expats on investing in a dual taxation world, managing finances, and planning for retirement.

Information

  • Creator
    The Expat Sage
  • Years Active
    2025 - 2026
  • Episodes
    37
  • Rating
    Clean
  • Copyright
    © 2026 The Expat Sage Podcast
  • Show Website
    The Expat Sage Podcast