Last Updated: April 2026
American retirees living abroad face a uniquely complex financial situation: two or more countries may have legitimate tax claims on their retirement income, the mechanics of US retirement accounts interact in unexpected ways with foreign tax laws, and rules that apply domestically — like the straightforward tax-free treatment of Roth IRA distributions — may not be recognised by the country where you actually live. A retiree who spent decades building wealth in the US through 401(k) plans, IRAs, and Social Security contributions may find that the country they retire to has different ideas about how that wealth should be taxed.
This guide covers the major US retirement income streams — Social Security, 401(k) distributions, traditional and Roth IRA distributions — and how they are taxed both by the US and by the most popular expat retirement destinations. It also covers the PFIC trap (one of the most damaging tax rules for Americans investing while abroad), FBAR compliance, and the state income tax implications of establishing domicile abroad or in a no-income-tax state before retiring.
Social Security retirement benefits remain subject to US federal income tax regardless of where you live. The US has non-negotiable taxation rights over Social Security paid to its citizens. The amount taxable depends on your “provisional income” calculation — a formula that combines AGI, tax-exempt interest income, and half of Social Security benefits received.
Provisional income = Adjusted Gross Income + Tax-Exempt Interest + 50% of Social Security Benefits. If provisional income is below $25,000 (single filers) or $32,000 (married filing jointly), 0% of benefits are taxable. If provisional income is $25,000–$34,000 (single) or $32,000–$44,000 (MFJ), up to 50% of benefits are taxable. If provisional income exceeds $34,000 (single) or $44,000 (MFJ), up to 85% of benefits are taxable. Note: these thresholds have never been inflation-adjusted since they were set in 1983 (50% tier) and 1993 (85% tier). As a result, an increasing share of retirees find that most or all of their benefits are taxable.
Whether your country of residence can also tax your US Social Security depends entirely on the bilateral tax treaty. Key treaty treatments: United Kingdom: The US-UK tax treaty (Article 17) grants exclusive US taxing rights to Social Security benefits paid to US citizens. The UK does not tax US Social Security received by US citizens resident in the UK. Canada: Canada does not tax US Social Security received by Canadians under the US-Canada tax treaty (Article XVIII). Note: conversely, Canadian CPP/OAS received by Americans in the US is taxed by the US as ordinary income (though treaty provides some relief). Germany: The US-Germany treaty treatment of Social Security is complex and has been subject to dispute. Generally, Germany does not tax US Social Security received by US citizens in Germany, but the income may be included for progressivity purposes (Progressionsvorbehalt), effectively increasing the rate applied to other German-source income. Countries Without a US Tax Treaty: If you retire to a country without a US income tax treaty (e.g., UAE, Thailand without treaty, much of Latin America outside a few countries), you rely entirely on domestic US law. The US taxes your Social Security; the non-treaty country applies its own rules. In low/zero-tax countries (UAE), this is not a problem. In countries with significant income tax, there is no treaty mechanism to prevent double taxation of Social Security.
The Social Security Administration pays benefits to most countries by direct deposit or check. A small number of countries are prohibited from receiving SSA payments under federal law: Cuba, North Korea, and a few others. If you retire to a country where SSA cannot pay directly, payments may be held or alternatives arranged. Verify your destination country’s SSA payment status at SSA.gov before committing to a retirement destination.
Traditional 401(k) and IRA distributions are fully taxable as ordinary income in the US regardless of where you live as a US citizen or green card holder. This is straightforward. The complexity arises when your country of residence also claims the right to tax those distributions under its domestic law — potentially resulting in double taxation on the same retirement income unless the treaty provides relief.
Most US tax treaties include an article covering pensions and retirement income. The typical structure gives primary taxing rights to the country of residence for private pension distributions, with a credit mechanism to offset the US tax already paid. In practice, this means: if you live in the UK and receive a $50,000 traditional IRA distribution, the UK would tax it as pension income, and you would claim a Foreign Tax Credit on your US return for UK taxes paid on that distribution. Since the UK rate on $50,000 income is likely close to or above the US rate, the FTC offsets most or all US tax liability. However, treaty provisions vary significantly in their exact language — always confirm the specific treaty article with a dual-qualified tax advisor.
A critical pre-retirement planning decision: establish domicile in a no-income-tax state (Florida, Texas, Nevada, Wyoming) before you begin taking significant 401(k) and IRA distributions. Many Americans retire to Florida or Texas domestically and then subsequently move abroad — retaining their Florida or Texas domicile as their US “home state” even while living in Portugal or Mexico. This eliminates state income tax on retirement distributions entirely. California, by contrast, taxes 401(k) and IRA distributions at rates up to 13.3% even if the recipient has moved abroad, as long as California considers them still a California domiciliary. A clean domicile change to a no-income-tax state before significant distribution events can save $5,000–20,000/year in state income tax.
RMDs begin at age 73 (for those who reach 72 after December 31, 2022) under the SECURE 2.0 Act. RMDs are mandatory annual withdrawals from traditional IRAs, 401(k)s, and most other pre-tax retirement accounts. Living abroad does not exempt you from RMDs — they are required under US law. Failure to take RMDs results in an excise tax of 25% of the required minimum amount (reduced to 10% if corrected within 2 years). Calculate your RMD each year using the IRS Uniform Lifetime Table applied to your December 31 account balance. Your custodian (Vanguard, Fidelity, Schwab) can typically calculate and distribute your RMD automatically.
Two areas create the most significant planning traps for Americans retiring abroad: the Roth IRA — beloved for its US tax-free treatment but not always recognised that way abroad — and the PFIC (Passive Foreign Investment Company) rules, which penalise Americans who hold foreign-domiciled investment funds.
In the United States, qualified Roth IRA distributions are completely federal income tax-free. Distributions are not included in provisional income for Social Security taxation purposes. This makes Roth conversions and Roth IRA accumulation highly valuable for retirement planning. However, several major expat retirement destinations do NOT recognise the tax-exempt nature of Roth IRAs under their domestic law, and treaty protections are limited.
United Kingdom: HMRC does not recognise the Roth IRA as a pension for UK tax purposes. Instead, HMRC treats a Roth IRA as a “settlement” or trust arrangement. This means that UK residents holding Roth IRAs may owe UK income tax on Roth IRA growth and distributions as if the account were taxable. This is a significant planning issue for Americans who retire to the UK. Specialist advice from a UK-US dual-qualified tax advisor is essential before relying on Roth IRA distributions as a UK resident.
France: The US-France tax treaty includes specific provisions that partially recognise the tax-deferred nature of US retirement accounts, but France’s treatment of Roth IRAs specifically is complex. Some distributions may benefit from favorable treatment under Article 18 of the treaty; others may be taxable. French tax authorities have taken varying positions over time. Professional guidance is required.
Germany: Germany partially recognises US IRAs and 401(k)s under the treaty. Contributions that were tax-deductible in the US are typically treated as pension income taxable by Germany on distribution. The Roth IRA is more complex as contributions were made with after-tax dollars, so Germany in principle should not tax the return of principal, only the earnings.
The most dangerous investment mistake for Americans abroad is purchasing non-US-domiciled investment funds — including what appear to be mainstream, low-cost index funds. Any mutual fund or ETF not domiciled in the United States is a Passive Foreign Investment Company (PFIC) for US tax purposes. The PFIC tax regime is explicitly punitive: All gains and excess distributions from PFICs are taxed at the highest ordinary income rate (37%), regardless of holding period (no 0%/15%/20% long-term capital gains rates). An interest charge is added, calculated as if the gain were earned evenly over the holding period, and taxed at the highest rate for each prior year. Example: a US citizen living in Germany purchases an Irish-domiciled Vanguard FTSE All World ETF (VWCE, a popular European fund). After 10 years, a $100,000 gain triggers PFIC rules. The gain is allocated across 10 years, taxed at 37% each year, plus interest on each year’s tax. Total tax could approach 50–60% of the gain. The same gain in a US-domiciled Vanguard fund (like VT, the US-listed equivalent) would be taxed at 20% long-term capital gains rate. Solution: hold all investment assets in US-domiciled funds. Vanguard US-listed ETFs, Fidelity US-listed mutual funds, and Schwab US-listed ETFs are all US-domiciled and not PFICs. Americans living abroad should never purchase ISA-held funds (UK), UCITS ETFs (EU), or any fund structured under non-US law.
Americans retiring abroad must maintain ongoing US reporting compliance that goes well beyond simply filing an annual tax return. The two primary foreign asset reporting requirements — FBAR (FinCEN 114) and FATCA (Form 8938) — apply regardless of tax owed and carry severe penalties for non-compliance. Managing US brokerage and retirement accounts from abroad adds an additional layer of complexity.
FinCEN Form 114 (FBAR) must be filed if your aggregate foreign financial account balances exceeded $10,000 at any point during the calendar year. “Aggregate” means the total across all foreign accounts — multiple accounts in multiple countries are summed. The $10,000 threshold is not per account; it is the total across all accounts at any single day during the year. For expat retirees, this threshold is almost always crossed: a local bank account to pay rent, utilities, and living expenses in Portugal or Mexico will regularly hold more than $10,000. FBAR is filed electronically via the FinCEN BSA E-Filing System (not the IRS), due April 15 with an automatic extension to October 15. Penalties for non-willful failure to file: up to $10,000 per account per year. Courts have disagreed on whether the $10,000 applies per form (all accounts) or per account (each account separately). IRS Criminal Investigation can pursue willful violations as criminal tax fraud.
Form 8938 (FATCA) is filed with your annual Form 1040 and requires disclosure of “specified foreign financial assets” above the following thresholds: Single taxpayers living abroad: $200,000 on the last day of the year, OR $300,000 at any point during the year. Married taxpayers living abroad filing jointly: $400,000 on the last day of the year, OR $600,000 at any point. Foreign financial assets for FATCA purposes include: foreign bank accounts, foreign brokerage accounts, interests in foreign entities, and foreign-issued life insurance with cash value. US-domiciled retirement accounts (401(k), IRA held at Fidelity or Vanguard) are NOT reported on Form 8938.
A practical and growing problem: US brokerage firms increasingly restrict accounts held by residents of certain foreign countries, particularly EU/EEA countries, due to regulatory compliance concerns (MiFID II in Europe restricts marketing of certain products to EU residents). Charles Schwab International, Interactive Brokers, and Fidelity are among the US brokerages that have historically served expat customers, though policies change. Critical: maintain your US brokerage accounts before leaving the US. Some firms close accounts when they discover the holder has become a foreign resident. Establish accounts with expat-friendly brokerages or confirm your broker’s policy before your move.
Medicare generally does not cover healthcare services outside the United States (with very limited exceptions for emergency care near the Canadian or Mexican border). Expat retirees relying on Medicare as their health insurance will have no coverage abroad. Options: local public health system (if your residence country permits you to enroll as a resident); private international health insurance; travel back to the US for significant medical care. International health insurance for retirees aged 65–75 can cost $3,000–10,000+/year depending on coverage level, destination country, and pre-existing conditions. Budget this into retirement income planning.
CountryTaxCalc.com is reader-supported. When you use our partner links, we may earn a commission at no cost to you. Learn more about our affiliate partnerships
★ 4.8 Trustpilot · 1,625 reviews
Greenback specialises in US expat tax returns for retirees abroad — Social Security reporting, foreign pension treatment, FBAR, FATCA, and retirement distribution planning.
⚠ Not the cheapest option — best for complex situations and expats who want a dedicated CPA.
Get Expert Expat Tax Help →★ 4.3 Trustpilot · 287,413 reviews
Wise makes it easy to receive US pension, Social Security, and IRA distributions in your local currency abroad with low fees and real exchange rates.
⚠ For currency exchange only — not a bank account replacement.
Receive Pension and SS Payments Abroad →Yes. The US taxes Social Security benefits based on provisional income (AGI + tax-exempt interest + 50% of Social Security benefits) regardless of where you live. Up to 85% of benefits may be taxable if your provisional income exceeds $34,000 (single) or $44,000 (married). Whether your country of residence also taxes your US Social Security depends on the bilateral tax treaty. The UK and Canada generally do NOT tax US Social Security received by US citizens under their respective treaties. Countries without a US treaty apply their own domestic rules.
You should not. Foreign-domiciled mutual funds and ETFs are Passive Foreign Investment Companies (PFICs) for US tax purposes, subject to punitive tax treatment: all gains taxed at the highest ordinary income rate (37%) plus an interest surcharge, with no long-term capital gains rates available. This applies to Irish-domiciled UCITS ETFs, UK ISA funds, and any non-US fund structure. Always hold US-domiciled funds (Vanguard US-listed ETFs, Fidelity or Schwab US index funds) in your investment accounts, even while living abroad. If you inherited or purchased foreign funds before understanding the PFIC rules, consult a tax attorney about mark-to-market elections or QEF elections to mitigate the impact.
Not necessarily. The UK does not recognise the Roth IRA as a pension for UK tax purposes. HMRC has treated Roth IRAs as settlements or trusts, potentially subjecting growth and distributions to UK income tax for UK-resident holders. This is one of the most significant and commonly overlooked planning issues for Americans retiring to the UK. Before relying on Roth distributions as a UK resident, consult a dual-qualified US-UK tax advisor who can confirm current HMRC guidance and any relevant treaty arguments. In contrast, traditional 401(k) and IRA distributions are more clearly covered by the US-UK treaty’s pension provisions.
You need to file FBAR if your aggregate foreign financial account balances exceeded $10,000 at ANY point during the calendar year — even for a single day. For most expat retirees with a local bank account for living expenses, this threshold is crossed regularly when rent, pension, or Social Security deposits are made. The $10,000 is the aggregate across all foreign accounts, not per account. FBAR is filed separately from your tax return via FinCEN BSA E-Filing, due April 15 with automatic extension to October 15. It is a free filing with no tax owed — it is purely a reporting requirement. The penalty for non-willful failure is up to $10,000/year; willful failure penalties are far more severe.