Victor Gersten, EA, CFP®, MS, MPAS™
The seven steps of building an investment plan do not change when you retire to Europe.
Two of them get considerably harder. And one new constraint appears that has no equivalent at home.
This is the Europe version of that sequence, written for American retirees, with Spain as the working example. It is general information, not advice about your own accounts.
Step 1: Define the goal
Retirement is the obvious goal. Living abroad tends to add others that were not on the list before.
Flights home for holidays, weddings and emergencies. A cushion for a possible return to the United States. Support for family in another country.
Those are real, recurring and often underestimated. Naming them now is what stops them being funded out of the long-term portfolio at the wrong moment.
Step 2: Attach a time horizon
Short term is up to three years. Medium is three to ten. Long is ten or more.
The horizon decides the investment, not the other way around.
For a retiree abroad there is a currency dimension too. Money you will spend in euros within a few years is a different asset from money you will spend in dollars in twenty. Decide which is which rather than holding one pool and hoping.
Step 3: Understand your cash flow, in two currencies
Work out what actually arrives and what actually goes out. Note which currency each is in.
Most American retirees in Spain receive dollars and spend euros. So the exchange rate quietly changes their spending power every year.
This is also the point to look at how retirement income will be taxed. A Spanish tax resident pays tax in Spain on worldwide income, while the United States continues to tax them as a citizen.
The foreign tax credit relieves the overlap. It does not remove the need to plan the order of withdrawals.
Step 4: Size the emergency fund for living abroad
The usual three to six months of expenses is a starting point. Abroad, two additions are worth making.
The first is genuine travel money. Enough to get home at short notice without selling an investment.
The second is a larger reserve if a return to the United States is plausible. Relocating back is expensive, and it tends to happen on someone else’s timetable rather than your own.
Step 5: Establish your real risk tolerance
The question is not what allocation the arithmetic recommends. It is what allocation you will still be holding after a bad year.
The most expensive mistake in investing is selling after a decline and not returning.
For a retiree there is a second consideration people miss. Sequence of returns risk means a poor stretch early in retirement does more damage than the same stretch later, because you are selling into it. A portfolio that suits a fifty year old still accumulating may not suit the same person two years into drawing on it.
There is also an inflation point specific to living abroad. A dollar-denominated portfolio has to keep pace with the cost of living in the city where you actually spend. That is not the same problem as keeping pace with US inflation.
Step 6: The account question is harder abroad
This is the first of the two steps that change materially.
Some US institutions restrict or close accounts once the address of record becomes foreign. The trigger is usually the address rather than your citizenship. Policies also differ between the brokerage arm and the retirement plan arm of the same firm.
The practical version of this step is simple. Ask each institution, in writing, what its policy is for a client who becomes tax resident in Spain. Keep the answer. Ask before you change the address, not after.
If a closure notice does arrive, the tax cost of the fix usually matters more than the closure itself. Why US Brokerages Are Closing Expat Accounts sets out the sequence.
One thing not to do is keep a US address you do not live at. It creates problems with the firm, with FATCA reporting and with Spanish residency questions.
Step 7: What you can actually buy
This is the constraint with no domestic equivalent. It is the reason generic investing advice fails Americans in Europe.
The US side
Nearly every non-US pooled fund is a passive foreign investment company.
The default treatment allocates a gain back across the holding period. It taxes the earlier slices at the highest ordinary rate in force for each of those years. It adds an interest charge. And each holding brings its own Form 8621.
That is what makes the Spanish fund your bank recommends the wrong purchase for you specifically.
The European side
The PRIIPs regulation means US-domiciled ETFs generally cannot be sold to EU-resident retail investors. US issuers do not publish the required Key Information Document. Many brokers block those purchases once your address is European.
So EU rules restrict buying American funds, and US tax rules punish owning European ones.
What remains is enough to build a proper portfolio. US-domiciled funds held in a US account that accepts your residence. Individual stocks and bonds. And the US retirement accounts you already hold. The PFIC Trap covers the detail.
The reporting that comes with it
Two obligations tend to arrive unannounced.
On the US side, foreign financial accounts exceeding $10,000 in aggregate at any point in the year trigger an FBAR. You file it with FinCEN rather than the IRS. Form 8938 is a separate IRS filing with much higher thresholds for taxpayers abroad. Filing one does not satisfy the other.
On the Spanish side, Modelo 720 covers assets held outside Spain, with a separate €50,000 threshold for each of three categories. Wealth tax may also apply above a state exempt minimum of €700,000 per taxpayer.
Frequently Asked Questions
Can I keep my US brokerage account after moving?
Often yes. It depends entirely on the institution. Confirm the policy in writing before changing your address of record, because that is what triggers the review.
Why can I not buy US ETFs from Spain?
EU rules require a Key Information Document in a prescribed format for products sold to retail investors. US issuers generally do not produce one. The restriction is on new purchases and it varies by broker.
What should an American in Europe actually hold?
Generally US-domiciled funds in a US account, individual securities, and existing US retirement accounts. What to avoid is locally sold pooled funds.
Do I pay tax twice on investment income?
Both countries may tax the same income. The foreign tax credit relieves the double charge. You claim it on a return filed afterward, so the sequencing still matters.
Working with a cross-border adviser
Steps 1 through 5 you can work through yourself.
Steps 6 and 7 are where people need help. The answer depends on US tax law, EU securities regulation and your specific custodian’s policy at the same time.
Cross Border Wealth Advisors is a fee-only fiduciary firm serving US citizens living in or moving to Spain. I hold both the CFP® certification and an Enrolled Agent license.
That matters here. For an American in Europe, what to own and what the tax return looks like are the same question.
Everything above is general information, not advice about your accounts.
To talk it through, book an introductory conversation at cbwealthadvisors.com or email info@cbwealthadvisors.com.
Sources
- IRS, Instructions for Form 8621
- IRS, Comparison of Form 8938 and FBAR requirements
- IRS, Foreign tax credit
- Agencia Tributaria, Modelo 720 FAQ
Related reading: Getting Started With Investing in 7 Steps · Investing in Europe as an American Retiree
Disclosures
This article is general educational information published by Cross Border Wealth Advisors, a company of Gersten Financial Planning Inc., an investment adviser registered with the State of California (CRD 309890). It is not investment, tax, legal or immigration advice.
Investing involves risk, including possible loss of principal. Diversification does not guarantee a profit or protect against loss. Past performance is not indicative of future results. Rules and figures change and are stated as of the date above. Cross Border Wealth Advisors is fee-only and receives no commissions. Registration does not imply a certain level of skill or training.
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