The Expat Sage Podcast

The Expat Sage

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. 21H AGO

    From Bargain To Luxury: Italy’s 2026 Tax Overhaul Explained

    Imagine watching the sun spark off the Mediterranean while your tax plan quietly does the heavy lifting. We pull back the curtain on Italy’s 2026 pivot from discount destination to premium club, and show exactly who still benefits, who pays more, and how to structure a smart move that lasts. The big swing is clear: the non-dom flat tax rises to 300,000 euro, dependent surcharges double, and yet for ultra–high net worth families with substantial foreign passive income, the effective rate can still be unbeatable. We explain the privacy edge, the Quadro RW exemption, and the nasty surprise hiding in qualified share sales within the first five years. If you’re moving to work, the inbound workers regime remains powerful but focused: a 50% exemption on Italian income, or 60% with a minor child, capped at 600,000 euro. Qualifications are tighter and the four-year commitment comes with clawbacks if you bail early. Here’s the unlock for the working wealthy: Ruling 199 lets you combine regimes, using the inbound workers relief for salary while covering global passive income with the 300K flat tax. Add fresh clarity for remote employees of foreign companies—no need for your employer to set up Italian payroll—and the path for modern, mobile professionals becomes far smoother. We also map the pressure points. Crypto investors face a hard reset with a 33% capital gains rate, no de minimis threshold, and a new wealth tax that doubles if you can’t prove wallet jurisdiction. By contrast, retirees still have a remarkable route: a 7% flat tax on all foreign income for ten years if you settle in small southern towns, and researchers enjoy the most generous treatment of all with a 90% exemption that can stretch to 13 years. Finally, we lay out the compliance beats—June 30 payments, IVE and IVAFE on foreign assets, and the new presumption that three or more short‑term rentals equals a business with VAT. Thinking about a move or a restructure after the UK ended non-dom status? This deep dive gives you the numbers, the strategy, and the traps to avoid so you can decide whether Italy’s premium price buys you premium value. If this helped clarify your next step, follow, share with a friend planning a move, and leave a quick review—what’s your optimal setup? More info at Comprehensive Analysis of the 2026 Italian Fiscal Landscape for New Residents. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    18 min
  2. FEB 7

    Surviving 2026: U.S.–Germany Tax Shocks, Exit Traps, And Smart Defenses

    The rules of the game just changed, and anyone living between the U.S. and Germany can feel the floor move. We unpack what actually shifted in 2026, why the headlines about a “1% transfer tax” missed the point, and how to build a defense that keeps more of what you earn. From business owners hit by NCTI to families blindsided by Germany’s new exit tax on ordinary funds, this conversation trades confusion for a clear plan. We start by killing the remittance panic with the banked exemption—digital, KYC‑compliant transfers remain untouched—then pivot to the bigger story: GILTI’s transformation into NCTI and the death of QBAI. For entrepreneurs with German companies, Section 962 becomes a lifeline, converting punishing U.S. exposure into a liability that can be wiped out by German corporate taxes when the election is filed correctly. On the personal side, we walk through the “millionaire next door” trap where steady ETF saving pushes a household over Germany’s 500,000 euro acquisition threshold, triggering a deemed sale on departure and a brutal liquidity crunch. The fixes—portfolio washing and spousal allocation—only work before deregistration, so timing is everything. Retirement isn’t spared. We explain how Germany now taxes full 401(k) distributions and treats Roth IRA growth as taxable, creating a foreign tax credit mismatch that can’t be papered over. Add the PFIC versus PRIIPs stalemate—penalties for European funds on the U.S. side and restricted access to U.S. ETFs on the EU side—and investing feels boxed in. We map three legal paths forward: options assignment to acquire U.S. ETFs, disciplined portfolios of individual stocks with improved German loss netting, and long‑horizon German real estate that becomes tax‑free after ten years. With the OBBBA locking the U.S. estate tax exemption at $15 million per person, most families can focus their estate planning energy on Germany’s lower allowances. The playbook is simple, not easy: stay banked, file the 962 election, manage acquisition cost before you move, and split assets into three buckets across jurisdictions. Subscribe for more deep, practical breakdowns of cross‑border money problems, and share this episode with a friend who needs a plan before 2026 turns their savings into a tax surprise. More info at Investing from Germany - Financial planning for US citizens moving to or living in Germany in 2026. If you have questions, contact us. Moving, Working, and Investing for Americans Abroad

    17 min
  3. JAN 31

    Guida al Sistema Fiscale USA per Non-Residenti: Affitti, Vendite e Pensioni

    Ti sei mai chiesto come funzionano le tasse americane quando vivi all'estero ma possiedi una casa negli Stati Uniti o ricevi redditi da fonti USA? Il nostro episodio approfondisce questo labirinto fiscale, offrendo una bussola per orientarsi tra regole complesse e opportunità spesso sconosciute. Partiamo dalla distinzione fondamentale tra essere "resident alien" o "non-resident alien", una classificazione che determina completamente il tuo destino fiscale. Scoprirai la differenza cruciale tra redditi ECI (Effectively Connected Income) e FDAP (Fixed Determinable Annual or Periodical), e come questa distinzione influisce drasticamente sulle aliquote fiscali applicabili e sulla possibilità di dedurre spese. Per i proprietari di immobili negli USA, sveliamo l'utilissima "Section 871(d) election" che può trasformare un pesante prelievo del 30% sul lordo in una tassazione più favorevole sul netto. Ti spieghiamo anche il temuto FIRPTA, che impone una ritenuta del 15% sulla vendita di proprietà americane, e come potenzialmente ridurla. Esploriamo inoltre il trattamento fiscale delle pensioni statunitensi, con particolare attenzione alla Social Security e ai piani pensionistici come 401(k) e Roth IRA. Il filo conduttore dell'episodio è l'importanza dei trattati fiscali tra gli USA e il tuo paese di residenza, veri e propri alleati che possono ridurre significativamente o addirittura azzerare molte imposte. Ti guidiamo attraverso il modulo W-8BEN, lo strumento essenziale per certificare la tua residenza estera e accedere ai benefici previsti dai trattati. La fiscalità internazionale è complessa e in continua evoluzione, per questo concludiamo con un consiglio prezioso: affidarsi a un professionista esperto può farti risparmiare molto più del suo onorario. Ascolta questo episodio per trasformare una selva di norme incomprensibili in una strategia fiscale vantaggiosa per i tuoi interessi americani.  Per saperne di piu' leggi gli articoli qui (in Inglese). Se hai domande contattaci. Moving, Working, and Investing for Americans Abroad

    10 min
  4. JAN 23

    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
  5. 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
  6. 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
  7. 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
  8. 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

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.