For Americans in Spain

Who we work with

Most people arrive here with a version of the same question: is my situation the kind of thing you actually handle, or am I about to spend twenty minutes finding out that I am not a fit.

So here are the six situations that come up most often. They are drawn from what people have told us when they book a call, and they are composites rather than descriptions of any individual client. If one of them sounds like your own position, that is the fastest way to know this is worth a conversation.

The couple with a date on the calendar

They have decided. What they do not have is an order of operations, and the window they are standing in closes on a day count rather than on their intentions.

"We know we are going. We do not know what to do first."
Usually fitsSettler

A sequenced pre-move plan, then four review meetings a year and tax preparation support in both countries.

You have picked the year, and probably the region. The house in the States is on the market or about to be. The 401(k) that took thirty years to build has quietly turned into a question instead of an answer.

What you are deciding is not really where to live. It is what to do in the months before Spanish residency begins, because most of the useful moves stop being available on the day it does. Spanish residency generally attaches once you pass 183 days in a calendar year, and it then applies to the whole of that year, including the months you were still in San Diego.

The questions that come up most often at this stage:
Whether to realize gains, exercise options or sell a business interest before the move rather than after
Whether a Roth conversion makes sense in a year when you are still taxed only by the United States
What happens to a California living trust when it lands in a civil law country with forced heirship rules
What the region you choose does to your transfer tax on a purchase, and to your annual wealth tax exposure
Which of your accounts your custodian will still hold once the address of record changes

Most people in this position do not need a permanent relationship with an adviser. They need the sequence right once, in the year that matters. That is what the first year of a Settler engagement is for: the plan is built in the first two to three months, and because there is no fixed time commitment, whether it continues after that is a decision for later.

The one who just found out

Not shopping for an adviser. Searching for the answer to a specific question that turned out to be worse than expected.

"I went looking for one answer and found a problem I did not know I had."
Usually fitsStart with the $499 Discovery meeting

A written read of your exposure and an order of operations, then Sailor or Settler if you want help carrying it out.

Something surfaced. Maybe your Spanish bank put you into a fondo de inversión three years ago and you have just learned what a passive foreign investment company is. Maybe your US brokerage sent a letter giving you sixty days. Maybe you read that the Modelo 720 penalties were struck down and worked out that the filing obligation was not. The feeling is usually the same: a mix of irritation that nobody mentioned it, and a quiet worry about how far back it goes.

Two things are worth saying plainly. The first is that this is a very common situation for people who relocate internationally, and there are well established procedures for correcting it properly. The second is that the order in which you fix it matters more than the speed. Selling a position to escape one problem can create a larger one on the other country's return, and a filing made in the wrong sequence can close options that were open the week before.

What this usually needs, to start, is a clear read of the actual exposure, a plan for unwinding it in a deliberate order, and coordination with the people who will do the filing on each side. The $499 Discovery meeting is built for exactly that.

Cross Border Wealth Advisors does not prepare tax returns in house. What we do is work out what you are holding, what it costs to keep and what it costs to exit on both returns, and then coordinate with a US preparer and a Spanish counterpart so the two sides agree.

The resident whose advisers have never spoken

Two competent professionals, one on each side, and nobody holding the question of which answer governs.

"I have a gestor and a US accountant. They have never spoken to each other."
Usually fitsSailor

An ongoing plan with three meetings a year and coordination between your gestor and your US preparer. Settler adds tax preparation support.

You moved two or three years ago. You found a gestor who files your Modelo 100, and you kept the US preparer who has done your 1040 for a decade. Both are good at their jobs. Neither has ever seen the other's work.

So you get two answers to the same question and no one whose job it is to say which one governs. Is your Social Security taxed here, there, or both. Did the fund your Spanish bank recommended quietly create a US filing obligation you have never heard of. Was the Modelo 720 supposed to be filed again this year, or only when something changed by more than a certain amount.

Meanwhile the decisions that actually cost money are the ones nobody has been asked to look at. Which account to draw from first, and in what order. Whether this is a good year to realize a gain or a bad one. What your US brokerage will do when it notices the Spanish address.

This is not a knowledge problem. Every individual piece has an answer. It is a coordination problem, and coordination is the thing that has no owner when the work is split across two firms in two countries.

The retiree living on US accounts

A lifetime of savings in dollars, a retirement in euros, and two governments with opinions about every withdrawal.

"Which account do I draw from first, and what does Spain do with it?"
Usually fitsSailor or Settler

A withdrawal and tax plan across your IRAs, 401(k) and Social Security. Settler adds portfolio management and tax preparation support.

You worked for decades in the States. Now the income comes from an IRA, a 401(k), maybe a pension, and Social Security, and you are living on it in a country that taxes each of those differently than the IRS does.

The treaty helps, but only when every distribution is classified and reported correctly on both returns. Spain generally taxes distributions from traditional US retirement accounts as income, while the United States may tax the same withdrawal on its own terms. The order in which you draw, the timing of any conversion and the year you take a lump sum can move the total bill by a meaningful amount.

What this work looks like in practice is a withdrawal plan: which accounts to use, in what order and in which years, with the Spanish and US tax effect of each choice modeled before you act. Add the Social Security and Medicare questions, required minimum distributions, and where your accounts can stay custodied once your address changes, and you have a plan that is built once and then kept current.

The business owner with a foot in each country

A company, a move and a personal plan that all have to point the same way.

"My business is in the States and I am moving to Spain. What happens to the company, and to me?"
Usually fitsFounder

Settler plus planning for the business owner, with tax preparation support up to $5,000 a year including autónomo reporting.

You own a business, or you are about to start one in Spain. It may be a US LLC or S corporation that you plan to keep running remotely, or work you will do as an autónomo once you arrive. Either way, the company and your personal finances stop being separate questions the day you become a Spanish resident.

How you pay yourself, where the income is taxed and which entity sits where all feed into the same two returns. A structure that works well in the United States can produce an unpleasant result in Spain, and the reverse is also true. These questions are best settled before the move, while the choices are still open.

Founder is our Settler service with planning for the business owner added. We plan the owner side of your finances, including how you are compensated and how the business income lands on your personal returns, and we coordinate with the corporate and legal professionals you already use. We do not form entities, run payroll or give legal advice, and corporate or entity tax returns are outside the personal tax preparation support.

The household where the wealth tax changes the decision

Assets large enough that the annual Spanish number, not the move itself, is what the whole plan turns on.

"Nobody told us Spain taxes what we own, not just what we earn."
Usually fitsSettler

Portfolio, tax and wealth tax planning built on the same assumptions, with four meetings a year.

You hold both passports, or you have been resident long enough that it makes little practical difference. You own property here. There is a trust or an entity on the US side, and probably a rental property that has been there so long you stopped thinking about it.

Then somebody mentions the Impuesto sobre el Patrimonio, and the conversation changes. Spain taxes net assets above an exempt minimum, every year, with a further national levy on larger fortunes above its own threshold. The regions treat it very
differently from one another, which means the choice between Madrid and Barcelona has an annual cost attached to it that has nothing to do with the price of an apartment.

At this level the questions stop being about any one account:
What is actually inside the wealth tax base, and what is exempt
How the region you live in changes the number, and whether that is worth acting on
What a US trust does under Spanish forced heirship rules, and what it does to your heirs' inheritance tax
Where investments should sit, given that Spain taxes distributions the United States treats as tax free
How the US return and the Spanish return get built on the same assumptions rather than reconciled afterward

This is the work that does not divide cleanly between a tax preparer and an investment manager, because at this size the tax answer and the portfolio answer determine each other.

If none of these is quite you

These six cover most of the people we speak to, and they do not cover everyone. We also work with Americans elsewhere in Europe, with families where one spouse is not a US citizen, and with people whose situation does not fit a category at all.

What matters more than the category is whether two tax systems are both reaching the same money. If they are, the conversation is probably worth having. If they are not, we will tell you that on the call and point you toward someone better suited, which costs you twenty minutes and nothing else.

Start with a free twenty minute call.

The first step is a free twenty minute call to work out whether this is a fit. Nothing to prepare and nothing to send in advance.

If it is a fit, the next step is a ninety minute working session where we go through your situation in depth and you receive a written summary of our observations and recommended next steps. That session is $499, and the full amount is credited toward your initial engagement fee if you sign a Sailor, Settler or Founder engagement within 90 days. If you decide not to, you still leave knowing what your main cross-border issues are and what it would cost to leave them alone.

If you would rather see numbers before you talk to anyone, the pricing page lists every package and what is included.

A personal financial guide to living & retiring in Spain.

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