Cross Border Optimization

Cross-Border Wealth Management Optimization for Americans in Spain

Living in Spain as a US citizen means navigating two tax systems, two legal frameworks, and investment restrictions that most advisors simply aren't equipped to handle. We are.

No minimum assets required
2
Tax systems coordinated
FATCA
FBAR & PFIC compliant
100%
Fee-only fiduciary
17+
Years of experience

What is Cross-Border Wealth Management Optimization?

A coordinated approach to financial planning that accounts for both your US obligations and your life in Spain - simultaneously, not as an afterthought.

We optimize investment and tax strategies for Americans residing in Spain - analyzing your current financial picture while simultaneously accounting for the tax implications and treaty requirements of both countries.

Our planning addresses host country taxes, US federal and state income taxes, and estate planning considerations across two distinct legal systems. Unlike most advisors who handle one country or the other, we were purpose-built for the intersection.

There are no minimum asset requirements. Whether you've just arrived in Spain or have been here for decades, we can analyze your current strategy and show you exactly where optimization is possible.

Host country & US federal/state tax planning
Estate planning across two legal systems
Treaty-aware investment & withdrawal strategy
No minimum asset requirements

What makes cross-border finance genuinely complex.

These are not theoretical problems - they are real obstacles that Americans in Spain encounter, often
only after it's too late to correct them.

01

Investment strategy restrictions

Strategies that worked in the US may not work in Spain. MIFID II regulations restrict EU residents from purchasing many US-based investment funds - unless you are working with a qualified US advisor who understands how to navigate those restrictions without compromising your portfolio.

02

Tax treatment of US accounts

Different countries treat investment accounts very differently. Roth IRAs, for example, receive tax-free treatment recognition in the UK and France under double taxation treaties - but not in Spain or Italy. Without careful planning, you can face unexpected tax bills on accounts you assumed were protected.

03

Breaking US state residency

Simply moving abroad does not end your US state tax obligations. Breaking state residency requires deliberate, documented action - selling property, closing accounts, changing vehicle registrations, and in some states, a formal declaration to state tax authorities. Getting this wrong is costly.

04

Estate planning across borders

Even a simple will may fail to distribute your assets as you intend if its stipulations conflict with Spain's succession laws. Trusts designed for US tax efficiency will not be effective in many other countries and may create unanticipated and punitive complications. Cross-border estate planning requires specialist coordination.

Every dimension of your cross-border financial life.

Our comprehensive planning covers every area where the intersection of two countries creates complexity - from daily tax exposure to long-term retirement and estate strategy.

International tax planning
US & Spanish obligations, coordinated
Currency risk management
USD/EUR exposure across your portfolio
Retirement abroad planning
IRA, pension & withdrawal strategy
US & non-US pension coordination
Cross-border plan integration
FATCA, FBAR & PFIC compliance
Reporting requirements, handled
Multinational family planning
Tax & estate for multi-country families
Estate planning for US citizens abroad
Wills & succession across two systems
Expat insurance
Coverage for US citizens living abroad
Education savings
Cross-border education funding strategy
Charitable giving
Tax-efficient philanthropy across borders

A comprehensive plan built around your situation.

Our financial plan is a detailed, in-depth analysis that covers every dimension of your financial life - investments, retirement, estate, taxes, and insurance - viewed through the lens of two countries.

We begin by answering the four questions most expats need clarity on - then build a coordinated strategy that holds up across both countries over the long term.

01
Can I retire early?
Modelled across your US and Spanish income sources
02
How much can I spend for financial independence?
Safe withdrawal rates factoring in currency and dual taxation
03
Is my portfolio optimised for my risk profile?
MIFID II-aware allocation across your accounts
04
How do I optimise my tax situation?
Treaty-aware planning across IRS and Hacienda
Plan includes
US–Spain tax treaty analysis Foreign tax issue expertise IRS forms & deadlines Global investment awareness

Cross-border finance — plain answers.

Tax treaties, foreign account rules, PFIC traps, and currency risk - the questions we answer every week. Ask us yours.

The Foreign Earned Income Exclusion (FEIE, claimed on IRS Form 2555) allows qualifying Americans abroad to exclude up to $126,500 (2024) of foreign-earned income — wages, salaries, and self-employment income — from US federal tax. It does not apply to passive income: Social Security, IRA and 401(k) distributions, dividends, interest, or rental income. Most retirees drawing investment and pension income benefit more from the Foreign Tax Credit (Form 1116) than the FEIE, and the two cannot be claimed on the same income.

A Passive Foreign Investment Company (PFIC) is any non-US mutual fund, ETF, or pooled investment vehicle — including European index funds, Spanish bank investment products, and virtually all UCITS funds. Americans who own PFICs face punitive US tax treatment: all gains are taxed at the highest ordinary income rate (currently 37%) plus an IRS interest charge, regardless of how long you held them or the normal capital gains rate that would otherwise apply. The solution is to hold investments through US-based custodians in US-domiciled funds — which is a core part of the portfolio management in our Settler package.

Yes — if the aggregate balance of all your foreign financial accounts exceeded $10,000 at any point during the calendar year, you must file FinCEN Form 114 (FBAR) by April 15, with an automatic extension to October 15. This covers Spanish bank accounts, brokerage accounts, and certain foreign pension accounts. Civil penalties for non-willful failure to file reach $10,000 per violation; willful violations carry penalties up to the greater of $100,000 or 50% of the account balance at the time of the violation — making compliance non-negotiable.

The Beckham Law (formally the Special Expatriate Tax Regime under Article 93 of Spain's IRPF Law) allows qualifying individuals who become Spanish tax residents due to a new employment to pay a flat 24% tax rate on Spanish-source income up to €600,000 for up to 6 years, instead of the progressive rates reaching 47%. Most American retirees and self-employed individuals do not qualify, as it requires relocation for a specific employment reason — but it warrants analysis before you register as a Spanish resident, because the election must be filed within 6 months of registration and cannot be applied retroactively.

Modelo 720 is Spain's annual declaration of overseas assets, required of Spanish tax residents who hold foreign assets exceeding €50,000 in any of three categories: bank accounts, investments and securities, and real estate. It must be filed between January 1 and March 31 covering the prior calendar year. Non-filing or material errors historically carried minimum penalties of €10,000 per category, though some penalties were moderated following an EU Court of Justice ruling in 2022. As a new Spanish resident with significant US financial accounts, this filing is almost certainly required in your first year.

US citizens living in Spain continue to receive Social Security benefits without reduction or interruption — there is no residency requirement to collect benefits you have earned. The US-Spain Totalization Agreement also means that if you contributed to both Social Security systems, you may combine credits from both countries to qualify for benefits you might not otherwise reach alone. As a Spanish tax resident, your Social Security income may be included in your Spanish IRPF depending on your total income level — we address this calculation in our ongoing advisory process.

Currency risk is real but manageable without expensive hedging instruments. The practical approach is cash flow planning: maintain a 3–6 month reserve of euros in a Spanish account to cover near-term expenses, transfer dollars to euros in tranches rather than all at once, and keep long-term investments in their natural currency. Formal hedging strategies (forward contracts, options) typically cost more than the risk they offset for the cash flow amounts most expats manage. We incorporate currency planning into the cash flow projections in your financial plan.

Free resource

Personal financial guide to living & retiring in Spain.

A comprehensive guide for Americans making the move — covering taxes, investments, healthcare, and retirement planning across two countries.

No spam — unsubscribe anytime.
Fee-only fiduciary · CFP® · IRS Enrolled Agent

A personal financial guide to living & retiring in Spain.

Download our free expat guide and join our email list for updates that actually apply to Americans in Spain.

No spam — unsubscribe anytime.