US citizens and green card holders face the unique challenge of being subject to US federal tax and the obligation to file US tax returns, regardless of where they live and work.

Our US tax advisors support private individuals with all aspects of their reporting, compliance and tax-residency complexities.

If you are a US citizen or green card holder living overseas, or a non-US citizen thinking of moving to or investing in the US, our expert team of US tax specialists can guide you through the complexities of the US tax system.

As part of a global private-client team, we draw on expertise from across jurisdictions to provide coordinated, multi-country advice to clients with US connections.

Dennis McEvoy

Partner, Global Mobility Services

KPMG Switzerland

mail
call

Benjamin Brackett

US Private Client Tax Expert, US Certified Public Accountant

KPMG Switzerland

mail
call

Understanding and overcoming current challenges

Correcting past non-compliance

Late filing can lead to substantial penalties if the Internal Revenue Service (IRS) identifies the issue before the taxpayer voluntarily corrects it. The Streamlined Foreign Offshore Procedures may provide relief for taxpayers whose non-compliance was non-willful; however, eligibility is limited and generally unavailable once the IRS has initiated an examination or otherwise contacts the taxpayer.

Acting promptly is essential to preserve available options and reduce potential financial exposure.

Offshore reporting and FBAR risk

US citizens, green card holders, and other US tax residents with Swiss bank accounts may need to file an FBAR (FinCEN Form 114) with the Financial Crimes Enforcement Network if the aggregate value of their foreign financial accounts exceeds USD 10,000 at any point during the year.

This requirement applies even if there is no US tax return filing obligation. Non-compliance can trigger significant penalties, creating unexpected compliance risks for Americans living abroad.

Worldwide taxation and filing obligations

US citizens and green card holders living in Switzerland remain subject to worldwide taxation under the Internal Revenue Code.

Even if Swiss taxes fully offset US liability through foreign tax credits, annual US filing obligations continue to apply.

Additional taxes, such as the 3.8% Net Investment Income Tax, may still arise and cannot be offset with foreign tax credits.

US tax residency exposure

Swiss citizens moving to the United States may become subject to worldwide taxation once they qualify as US tax residents under IRC §7701(b).

Ownership of foreign companies, trusts or partnerships can trigger complex reporting requirements, and state-level tax systems may create additional liabilities.

US real estate tax complexity

Swiss residents purchasing US property may face exposure to US income tax, capital gains tax and estate tax.

Non-resident aliens are generally entitled to only a USD 60,000 estate tax exemption on US situs assets, meaning that without proper structuring, buyers may face unexpected estate tax liabilities and withholding obligations.

Limited relief after moving to Switzerland

US citizens relocating to Switzerland remain subject to US federal income tax on their worldwide income.

Certain Swiss taxes, such as cantonal wealth tax and church tax, are generally not creditable under the US foreign tax credit rules set out in IRC §901-904.

Why KPMG services?

Tax risk minimization

Our team has helped many clients avoid unnecessary tax risks and identify viable alternatives.

US and Swiss tax returns

We support you with your tax filing obligations in the United States and Switzerland.

Coordinated tax advice

Together with our Swiss specialists, we offer coordinated US and Swiss tax advice from an experienced, well-established team.

Navigating success: our proven approach

During our initial contact, whether in person or via video call, we take the time to get to know you and understand your unique needs.

Based on the information discussed, our team develops a tailored tax strategy and customized solutions.

Throughout the process, we remain available to answer your questions and provide ongoing support.

US tax advisory services for US citizens living outside the US

KPMG advises US citizens living and working abroad on how US tax rules interact with foreign tax systems. Our services include evaluating US tax residency status, assessing eligibility for the foreign earned income exclusion and foreign tax credits, and advising on foreign pensions, investment structures and passive foreign investment companies (PFICs).

We also advise on the US tax treatment of equity compensation, cross-border employment arrangements and the considerations involved in renouncing US citizenship, helping clients navigate long-term compliance and planning wherever they live.

US tax advisory services for non-US citizens moving to or investing in the US

For non-US citizens relocating to the United States or acquiring US-situs assets, KPMG provides advisory services aimed at anticipating and managing US tax exposure. This includes pre-immigration planning to determine when US tax residency begins and how best to structure finances ahead of the move, as well as guidance on inbound investment in US real estate, businesses and financial assets.

We also advise on US withholding-tax rules, the application of income-tax treaty and ongoing cross-border considerations for individuals maintaining ties to both US and non-US jurisdictions.

US estate and gift tax planning for cross-border individuals

KPMG advises US citizens living abroad as well as non-US citizens who own or plan to own US assets on exposure to US estate, gift and generation-skipping transfer taxes. For US persons, these rules apply to worldwide assets; for non-US persons, the focus is on US-situs assets and the more limited treaty protections available to them.

Our services include structuring the ownership of US real estate, business interests and financial investments in a manner consistent with long-term succession and wealth-transfer goals, while aiming to mitigate double taxation across jurisdictions. We also advise on the use of trusts, lifetime gifting strategies and coordination with foreign estate-planning counsel to support efficient and compliant cross-border wealth transfer.

Individual US income tax return filing
services

KPMG prepares and files US federal and state individual income tax returns for individuals with cross-border and international ties.

Engagements typically include preparing Form 1040 and all required schedules, reporting foreign-source income, foreign tax credits and foreign retirement arrangements, as well as addressing US reporting obligations for interests in non-US companies, partnerships and trusts.

Where beneficial, our team coordinates with local-country tax advisers to help manage double taxation and align each client's global tax position with their broader financial objectives.