Moving to the USA with wealth: what both sides tax

If you move to the USA with wealth, you deal with two tax systems that meet on a single day. The old one wants to settle up one last time when you leave; the new one wants to know what you own from day one, even if it sits in Europe. This article shows what the USA wants you to report and which topics to settle with your advisors on both sides before the move.

If you move to the USA with wealth, you deal with two tax systems that meet on a single day. The old one wants to settle up one last time when you leave; the new one wants to know what you own from day one, even if it sits in Europe. This article shows which reports await you in the USA and which topics to settle with your advisors on both sides before the move. It is an overview, not advice for your specific case and not an investment recommendation.

1Two tax systems, one cut-off date

It all starts with one question that decides almost everything else: from when are you a US tax resident? If you arrive with a green card and don't meet the Substantial Presence Test in the same year, you are resident from the first day you are in the country as a green card holder. If you come on a visa such as the E-2 or L-1, you become resident through the Substantial Presence Test: at least 31 days in the current year and 183 days in a weighted total over three years, where days in the current year count in full, days in the prior year count as one third and days in the year before that as one sixth. Exactly where the cut-off falls in your moving year, and which elections are available, is covered in our article on the moving year on your US tax return.

From that date, the IRS treats you like an American. According to the agency, a resident is generally taxed the same way as a US citizen and must report interest, dividends, wages, rents and all other income, whether it arises inside or outside the USA. Before that date, the law of your home country applies, and that usually doesn't end the moment you board the plane but when you give up your residence and habitual abode. Between those two points lies the window where planning is possible, and where mistakes get most expensive.

4Switzerland: tax-free capital gains and the pension fund

Switzerland doesn't have this problem in the same form. Under Art. 16(3) of the Federal Act on Direct Federal Taxation, capital gains from the sale of private assets are tax-free. Where no taxable gain arises, there is none for the move to trigger. Business assets and holdings in business assets follow different rules; that belongs in a consultation.

For many Swiss residents, the second pillar matters more. If you leave Switzerland for good to settle abroad, you can take your occupational pension savings as a lump sum in cash. Married people need their spouse's written consent. According to the Federal Social Insurance Office, the restriction that the mandatory portion is not paid out applies to moves to the EU, Iceland and Norway if you remain insured there, but not to the USA. Benefits from pension funds and recognized forms of tied private pension plans paid to recipients living abroad are subject to withholding tax (Art. 96 DBG). Whether you take the capital or leave it in Switzerland is a question for your retirement planning, not for a rule of thumb.

5Bringing money to the USA

There is no cap on the money you can wire to the USA. If you carry cash or other monetary instruments worth more than $10,000 when entering or leaving, you must report it to US Customs and Border Protection (CBP) on FinCEN Form 105. That is a report, not a ban. Larger sums arrive by wire transfer, and how they land in an American account is explained in our article on wiring money to an American bank account.

Keep the documents that show where your money comes from: sale contracts, portfolio statements, inheritance papers, tax assessments. For the E-2 and the EB-5, proof of the source of funds is part of the application anyway; what the authorities want to see is covered under E-2: source of funds and EB-5: source of funds. How to open your first account after you arrive is explained in our article on your bank account after the move.

6From day one: what the IRS wants to know

Residency triggers reporting obligations that many Europeans have never heard of. They apply whether or not any US tax is due on the assets.

The FBAR covers accounts and securities accounts at financial institutions outside the US in which you have an interest or over which you have signature authority, once their combined value exceeds $10,000 at any point during the year. It is due on April 15, with an automatic extension to October 15. Whether the account earns anything makes no difference. Alongside it sits Form 8938 under FATCA for foreign financial assets, with its own thresholds: if you live in the US and are single, you report once you hold more than $50,000 at year end or more than $75,000 at any point during the year; for joint filers it is $100,000 or $150,000. The two reports overlap, but one does not replace the other.

If you receive gifts or an inheritance from parents or relatives in Europe, you report it on Form 3520 when it totals more than $100,000 in a year from a non-resident individual or a foreign estate; every single gift over $5,000 must be listed. European funds and ETFs can count as a Passive Foreign Investment Company: according to the IRS, a foreign company is a PFIC if at least 75 % of its income is passive or at least 50 % of its assets produce passive income. That triggers Form 8621 and its own tax treatment, depending on whether the fund is treated as a Section 1291 fund or a QEF election is available; our article on PFICs and ETFs explains it. And if you keep a stake in a company at home, check your obligations under Form 5471 for US persons with interests in foreign corporations.

7Inheritance and gifts on both sides

According to the IRS, US citizens and residents are generally subject to the same income, estate and gift tax rules whether they live in the US or abroad. Under the OBBBA, the basic exclusion amount for 2026 is $15,000,000. Gifts of up to $19,000 per recipient per year stay outside the calculation; for a spouse who is not a US citizen, the figure is $194,000 in 2026. Non-Americans without US residence fall under different rules, covered in our article on US estate tax for non-US citizens.

8Pre-immigration planning: the topics for your consultation

Planning before you immigrate is not about avoiding tax. It is about getting the order right, so nothing is taxed twice or earlier than necessary and no filing slips through the cracks. Which steps are right for you depends on your assets, your visa and your home country. So the list below is not a recommendation; it is the set of topics to work through together with your accountant at home and your advisor in the US:

• Cut-off date: When do you stop being resident at home and start being resident in the US, and is there a gap or an overlap in between?
• Gains in value: Which gains have built up by the cut-off date, and which country taxes them if you sell before or after?
• Funds and ETFs: Which holdings could count as a PFIC after the move, and what that means for reporting and tax.
• Retirement savings: Pension funds, private pension plans, life and annuity insurance, and how the US treats them.
• Property at home: Renting, selling or holding, and which country taxes the rental income.
• Foundations and trusts: Whether you hold an interest in a structure or receive distributions from one.
• Accounts: Which accounts and securities accounts you keep in Europe, and who handles the FBAR and FATCA filings.

A word on sequence: the visa often determines when the cut-off date arrives, and the cut-off date determines the tax. That is why it pays to look at your visa and your assets in one plan. What else the move costs is covered in What does it cost to move to the USA, and the overall pros and cons of life in America in Pros and cons, honestly counted.

In short

• In Switzerland, private capital gains are tax-free; on a permanent move to the US, the pension fund can be paid out in full as cash, subject to withholding tax.
• Once you are a US resident, you report foreign accounts (FBAR above $10,000), financial assets (Form 8938), gifts from abroad (Form 3520) and fund holdings (Form 8621).

How we help you

• Visa RoadmapIn writing: which visa fits you and your family, prepared with the immigration attorney on the firm's team.
• US Tax ConsultationYour US tax question, answered by people who know both sides.
• Your US Tax ReturnForm 1040 or 1040-NR, handled in English.
• Moving to the USAVisa, bank account, taxes and where to live: your move with Mount Bonnell Advisors.