Before You Move to the US from China: Your Financial Checklist

China participates in the global financial information-sharing network. Your bank has been reporting your account details since 2018. Before you become a US resident, you need to know what that means for your accounts.

Wei assumed his Chinese A-share brokerage account was invisible to the IRS. He'd heard about tensions between China and the US on financial matters. What he hadn't read was that China joined the Common Reporting Standard in 2018. His Chinese bank had been automatically reporting his account information to the Chinese tax authority, which shares data with the IRS under FATCA reciprocity. The IRS knew about the account before Wei had thought to mention it.

This checklist covers what to do with your Chinese financial accounts before and after you become a US resident alien.

6 Months Before Departure

Audit your Chinese brokerage account

Chinese A-shares and Chinese-domiciled equity funds in a Chinese brokerage account are PFICs (Passive Foreign Investment Companies) from the moment you become a US resident alien. PFIC treatment in the US is punitive: gains are taxed as ordinary income at the highest marginal rate plus an interest charge, not at capital gains rates. For long-held positions in Chinese equity funds, the tax cost of holding them as a US resident can exceed the gain itself over time.

Before you leave China, evaluate whether to liquidate the brokerage account. Selling while you're a Chinese tax resident avoids the US PFIC complication entirely — the gain is taxed under Chinese rules, which are often more favorable, and the clean exit means you start US residency without PFIC exposure.

If you choose to hold, you'll need to file Form 8621 with your US return for each PFIC you hold. The "mark-to-market" election is the most straightforward PFIC reporting approach for most situations — it taxes gains each year as ordinary income, avoiding the interest-charge trap. Your US CPA needs to know about every Chinese equity holding.

Review Wealth Management Products (WMPs)

Chinese bank-sold WMPs (理财产品, lǐcái chǎnpǐn) are structured investment products commonly held by Chinese savers as an alternative to bank deposits. From a US tax perspective, many WMPs are PFICs or have PFIC characteristics depending on their underlying asset structure. Before you leave, evaluate whether to redeem these products. Redemption while a Chinese resident is straightforward. Holding them while a US resident creates annual reporting complexity.

Document all account balances for FBAR baseline

Once you become a US resident alien, FBAR (FinCEN 114) reporting applies to all foreign financial accounts with an aggregate balance exceeding $10,000 at any point during the year. This includes Chinese bank accounts, Chinese brokerage accounts, and possibly digital payment platforms.

Document the balance of every Chinese account before you leave. This establishes your baseline and makes the first FBAR filing more straightforward.

30 Days Before Departure

WeChat Pay and Alipay balances

WeChat Pay (微信支付) and Alipay (支付宝) balance accounts that exceed $10,000 in aggregate are subject to FBAR reporting once you're a US resident. This surprises most people. Mobile payment platforms are foreign financial accounts under the Bank Secrecy Act if they hold funds (as distinct from functioning purely as payment processors).

If you maintain meaningful balances in these accounts after becoming a US resident, they're FBAR-reportable. The simplest approach: reduce balances to minimal levels before departure.

Chinese company equity documentation

If you hold stock options or RSUs from a Chinese employer — whether a listed A-share company, an H-share company, or a Chinese tech company listed on a US exchange — gather the grant documentation, vesting schedule, and current fair market value estimates. The US tax treatment depends on the company's listing, whether the equity plan qualifies under IRC Section 83, and how income will be sourced between China and the US for the vesting period.

The US-China DTAA exists but predates modern equity compensation. Its application to RSUs and stock options from Chinese employers is ambiguous. You'll need a CPA with specific cross-border US-China expertise, not just a general international tax practitioner.

First 90 Days in the US

Establish your FBAR reporting baseline

Your FBAR obligation begins from the first day you become a US resident alien. For H-1B holders arriving mid-year, the first full FBAR year is the following calendar year, but if you hold accounts above the threshold during the year of arrival, those accounts are reportable for the partial year as well.

File FinCEN 114 annually by April 15 (auto-extension to October 15 available). The filing is online and doesn't generate a tax bill — it's a disclosure document. Willful non-filing carries severe civil penalties ($10,000 per non-willful violation, up to the greater of $100,000 or 50% of the account balance per willful violation). This is not a form to skip.

CRS implications: you were already being reported

China's participation in CRS means your Chinese financial institution has already submitted information about your accounts to the Chinese State Administration of Taxation (SAT), which exchanges that information with the IRS under the FATCA intergovernmental agreement. This is not a future event — it has been happening since 2018.

The practical implication: the IRS likely already has information about your major Chinese accounts. If you fail to report those accounts on your US tax return and FBAR, the IRS has the information to identify the discrepancy. Compliance is not optional.

Ongoing Obligations

FBAR (FinCEN 114): Annual, as long as aggregate foreign account balances exceed $10,000 at any point during the year. Covers all Chinese bank accounts, brokerage accounts, and payment platform balances.

FATCA (Form 8938): If aggregate foreign financial assets exceed $50,000 at year-end or $75,000 at any point (single filer, residing in US), file Form 8938 with your 1040.

Form 8621 (PFIC): Required annually for each PFIC you hold. If you kept Chinese mutual funds or WMPs, this form is mandatory.

Chinese income: All income earned in China while you were a Chinese resident is generally not US-taxable (pre-residency income). Income earned in China while a US resident is US-taxable and may also be taxable in China, with the FTC mechanism handling double taxation.