Before You Move to the US from Europe: The Financial Checklist for German, Dutch, and French Professionals
Your German bAV, Dutch pension, and French assurance-vie do not work the way you expect in the US. Each has its own problem. Each has a window for managing it.
Thomas had been contributing to his German bAV (betriebliche Altersvorsorge, occupational pension) for nine years. He assumed pensions were broadly similar globally — tax-deferred accumulation, taxable distribution. When he moved to the US on an L-1, his cross-border accountant explained that his German employer's contributions to the bAV — which Germany treated as tax-deferred — were still taxable US income in the year contributed. Germany's pension tax deferral is a German decision. The US didn't agree to it.
He'd been paying German tax relief on contributions he also needed to report as US income.
Germany
bAV (Betriebliche Altersvorsorge): the pension that isn't deferred in the US
German employer contributions to a bAV are not treated as tax-deferred in the US. There is no equivalent of the 401K recognition that the US-Canada treaty provides for RRSPs, or the pension treaty provisions in the US-UK treaty. The US-Germany tax treaty covers pension distributions but does not create a deferral mechanism for ongoing contributions.
Practical implication: once you're a US resident, employer bAV contributions may be reportable as gross income on your US return. This creates a situation where you're paying current-year US income tax on money that won't be accessible until German retirement age. Evaluate with your CPA whether to ask your employer to reduce or restructure bAV contributions during your US assignment.
Riester-Rente: no US treaty recognition
The Riester-Rente is a German government-subsidized private pension. It receives favorable tax treatment in Germany. The US does not recognize the Riester-Rente under any treaty provision. Contributions from your US income are not US tax-deductible. The underlying fund growth may be subject to PFIC rules depending on how the plan invests. German government subsidies paid into your Riester account may constitute US taxable income in the year received.
If you're departing Germany for the US permanently, evaluate whether to stop Riester contributions. New contributions as a US resident create US tax reporting complexity without US tax benefit.
German brokerage account: PFIC analysis
German-domiciled investment funds (including common investment vehicles sold through Deutsche Bank, DWS, or independent fund platforms) are PFICs for US persons. If you hold German mutual funds or ETFs in a German brokerage account, they require Form 8621 reporting after you become a US resident.
The practical solution: liquidate German-domiciled fund holdings before becoming a US resident. Hold German stocks directly (individual shares are not PFICs) or via US-listed ETFs that provide German or European exposure. iShares and Vanguard offer US-domiciled ETFs tracking German or European indices — these are not PFICs.
Netherlands
30% ruling: pre-arrival coordination if offered by a Dutch employer
If you're moving to the US via a Dutch employer who is offering an assignment to the US, and that employer has previously applied a 30% ruling for your Dutch employment, the 30% ruling does not transfer. The ruling is tied to Dutch employment and Dutch residency. It has no effect on your US tax situation.
If you're relocating from the Netherlands to the US and you previously benefited from the 30% ruling, your Dutch income during the ruling period should have been partially tax-free in the Netherlands. The US treatment of that income depends on whether you were a US person during the Dutch ruling period. If you were a US person (citizen or green card holder), you may have had US reporting obligations on the Dutch income even during the 30% ruling period.
NN/ABP pension entitlements
Dutch workplace pensions (NN, ABP for government workers, and other Dutch pension funds) have US treaty coverage under the US-Netherlands treaty. The treaty allows for deferral of US tax on pension growth if you claim the treaty position annually. Distributions in retirement are taxable in the US.
Document your Dutch pension entitlements before departure — the pension fund reference number, your accrued entitlement in euros, and the pension fund's contact information. You'll need this for annual treaty disclosures and eventually for distribution planning.
France
PERCO (Plan d'Épargne pour la Retraite Collectif)
The PERCO is a French employer retirement savings plan. Unlike the German bAV situation, the US-France tax treaty is more explicit — French qualified retirement plans are recognized for treaty purposes, allowing tax deferral on employer contributions. But the PERCO has specific conditions that determine whether it qualifies, and your employer's plan structure matters.
Before leaving France, get the PERCO plan documentation. Your US CPA will need to evaluate whether the specific PERCO qualifies for treaty treatment and how to report ongoing French employer contributions.
Assurance-vie: complex US treatment
French assurance-vie (life insurance/savings wrapper) is popular in France for its tax advantages. The US treatment depends on the underlying structure. If the assurance-vie invests in French-domiciled funds, PFIC issues arise. If the policy qualifies as a life insurance contract under US tax law (which some French policies do and some don't), it may receive different treatment.
This is one of the more complex areas. Before departing France, evaluate whether to cash out the assurance-vie before you become a US resident. Cashing out while a French resident means paying French tax (which may be minimal after the 8-year holding period). Holding it while a US resident requires analysis of the policy structure, the underlying assets, and the applicable treaty provisions.
PEA (Plan d'Épargne en Actions)
The PEA is a French tax-advantaged stock savings plan. The IRS does not recognize the PEA wrapper as tax-exempt. Gains inside a PEA are US-taxable in the year they accrue. French stocks held inside a PEA are still individual stocks (not PFICs), but the tax-free wrapper doesn't transfer. Consider liquidating your PEA before departure if the French tax cost is manageable.
Across All Three Countries: Common Obligations
FBAR: All European bank accounts, pension accounts, and investment accounts exceeding $10,000 in aggregate are FBAR-reportable once you're a US resident.
FATCA participation: Germany, Netherlands, and France all participate in FATCA under intergovernmental agreements. Your European financial institutions have been reporting your account information to local tax authorities, which share with the IRS. Compliance is not optional.
EU property: Rental income from European property held while a US resident is US-taxable. The property itself is not a financial account for FBAR purposes, but accounts receiving rental income are.
European social insurance records: Germany, Netherlands, and France each have state pension systems. Review your contribution records in each country before departure. US totalization agreements with all three countries prevent double Social Security contributions for US-assigned workers and preserve entitlement to benefits from both systems based on combined contribution records.
Get a CPA who knows both sides
The US-Germany, US-Netherlands, and US-France treaty networks are among the more comprehensive bilateral tax agreements the US has. But comprehensive doesn't mean simple. The treaty position on bAV contributions differs from the treaty position on pension distributions. The French PERCO analysis is genuinely complex. A US CPA without specific cross-border European experience will miss treaty positions that benefit you and may fail to identify reporting obligations. Find someone who has filed for European professionals moving to the US — not someone who says they handle "international" cases.
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