Austria's exit tax is less well-known than Germany's Wegzugsteuer or France's impôt de sortie, but it operates on similar principles — applying to unrealised capital gains in securities and company stakes when you transfer your Austrian tax residence abroad. The Austrian exit tax (Wegzugsbesteuerung) under §27a EStG is broad in scope but offers an EU/EEA deferral mechanism. Austria's unique 'Abfertigung Neu' (BV-Kasse — severance pay savings system) is an important financial asset for long-term Austrian employees that can be accessed on departure. Vienna's large international community of diplomatic and multinational employees creates particular relevance for this guide.
Austria-to-USA migration occurs among tech workers (especially Vienna's startup scene), academics, and corporate transferees. Key AT-US planning points:
Wegzugsbesteuerung (exit tax) and US first-year residency: The Austrian exit tax assessment occurs on the departure date. If you depart Austria and become a US tax resident later, the Austrian deemed disposal gains are pre-US-residency — not US-taxable. Ensure the timing of US residency commencement is after the Austrian departure date. Austrian taxes paid on the exit tax (if non-EU departure) generate FTC carryforwards in the USA.
BV-Kasse withdrawal before US residency: If you can receive the BV-Kasse lump sum before becoming a US tax resident (while the withdrawal is processed post-departure), it may not be US-taxable. The 6% Austrian flat tax is withheld; as a pre-US-residency receipt, the US cannot tax it. Timing is critical — work with a cross-border advisor.
Austria-USA DTA: The 1996 Austria-USA DTA governs double taxation. Austrian dividends: 15% withholding (5% for qualifying companies); creditable on US return. Pensions: residence country (USA) taxes; Austrian withholding credited. Austrian real estate: Austria retains taxing rights; US provides FTC.
FBAR for Austrian accounts: Austrian bank accounts exceeding $10,000 must be reported on FinCEN Form 114 annually as a US resident.
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