Europeans in the US moving back to Europe: the money questions
A European leaving the US faces the reverse of the American expat's problems, and they are just as easy to get wrong. Vested RSUs and options can be taxed by both countries on the same income, the 401(k) and IRA become foreign accounts that France, Germany or Finland tax on their own terms, California can keep claiming you after you have left, and a long-held green card can trigger the US exit tax. Almost every decision is cheaper before the departure date than after it.
- Equity follows you home — RSUs and options that vested over years of US work are typically allocated between the US and your home country, so the same grant can be taxed twice without treaty relief claimed correctly.
- The 401(k) does not travel — it stays a US account, and how withdrawals are taxed depends entirely on the treaty with the country you land in; France and Germany give different answers.
- California does not let go easily — the state presumes you are still resident if you keep ties, and its safe-harbor rules are narrower than people expect.
- Green card holders can face the US exit tax — eight of the last fifteen years as a lawful permanent resident makes you a long-term resident, and giving up the card can trigger the covered-expatriate rules.
Equity, RSUs and options
The grants you earned in US tech, taxed on both sides of the move.
- Should I sell my RSUs before leaving the US? — Deciding whether to sell RSUs depends on the tax rate differential between the US and your destination country. Generally, selling vested shares while a US resident ensures you pay US capital gains rates (often lower than European rates) and avoids complex foreign reporting. However, unvested RSUs will likely be taxed proportionately by both countries based on work days.
- What happens to my unvested stock options and RSUs when I move back to Europe? — Unvested equity is usually taxed proportionately by both the US and your new European home country. The US taxes the portion earned while working in the US, while your home country taxes the full amount but typically grants a credit for the US portion. You will need to track 'US work days' to ensure correct withholding.
The 401(k), IRA and US accounts
What stays, what moves, and what your broker will still let you hold.
- What happens to my 401(k) when I leave the US and move back to Europe? — You can typically keep your 401(k) in the US after moving back to Europe, where it continues to grow tax-deferred under most bilateral tax treaties. However, you generally cannot contribute further, and your broker may limit your investment choices. Liquidating the account early usually triggers a 10% US penalty plus immediate taxation in both countries.
- Can I keep my IRA or Roth IRA after moving back to Europe? — Yes, you can keep a US IRA or Roth IRA when moving to Europe, but its treatment varies by country. While traditional IRAs are generally recognized as tax-deferred by treaties, Roth IRAs are not always granted tax-free status in Europe (e.g., in Germany or France). Additionally, many US brokers will restrict your ability to trade within the account once you move.
- Should I roll my 401(k) into an IRA before leaving the US? — Rolling a 401(k) to an IRA before moving back to Europe offers more investment flexibility and potentially lower fees, but you may lose federal creditor protection and certain tax treaty benefits. Some treaties (like the US-France treaty) provide clearer protection for 'employer-sponsored' plans than for individual IRAs.
- Will my US brokerage close my account when I move back to Europe? — Many major US brokerages, including Vanguard, Fidelity, and Merrill Lynch, often restrict or close accounts once you provide a European address. This is due to EU regulations (MiFID II) and the high cost of US compliance for non-residents. Switching to an international-friendly broker like Interactive Brokers is often necessary.
US tax after you leave
California's long arm, filing obligations, and the green card exit tax.
- Does California still tax me after I move back to Europe? — California will stop taxing your global income once you break residency and domicile. However, California taxes all income with a 'California source,' including RSUs that vested while you worked in the state, even if you are now in Europe. To stop being a resident, you must clearly establish a new permanent home (domicile) abroad.
- Do I still file US taxes after moving back to Europe as a non-citizen? — You must file US taxes for the year you leave (as a dual-status alien) and in future years if you have US-source income like RSUs, US rental income, or if you still hold a green card. If you are a 'long-term' green card holder, you may also have a final expatriation filing requirement (Form 8854).
- I have a green card and I'm moving back to Europe — does the US exit tax apply to me? — The US exit tax applies if you are a 'long-term resident' (holding a green card in 8 of the last 15 years) and meet one of three 'covered expatriate' tests: a net worth over $2M, a high average tax liability, or a failure to certify 5 years of tax compliance. If covered, your global assets are 'deemed sold' for tax purposes.
Landing in France, Germany or Finland
What your home country does with your US pensions, funds and savings.
- I'm French, working in US tech — what taxes apply when I move back to France? — French residents are taxed on their worldwide income. Under the US–France tax treaty, a 401(k) or IRA paid to a French resident who is not a US citizen is taxable only in France, while US Social Security stays taxable only in the US. On return you must declare every US account (Form 3916), pay French tax on US dividends and gains (the 31.4% flat tax from 2026), and plan RSU vests that straddle the move.
- I'm German, working in US tech — what taxes apply when I move back to Germany? — Germany taxes residents on worldwide income. Your US brokerage account will be subject to German capital gains tax (Abgeltungsteuer) and the complex 'Vorabpauschale' tax on unrealized gains for non-distributing funds. The US–Germany treaty generally lets your 401(k) grow untaxed until you withdraw. How Germany treats a Roth IRA is less settled.
- I'm Finnish, working in US tech — what taxes apply when I move back to Finland? — Finland usually considers citizens tax-resident for three years after leaving (the 'three-year rule'), but for those returning, residency starts immediately upon arrival. You will be taxed on worldwide income, including US dividends and RSUs. Under the US–Finland treaty, private US pensions such as 401(k) distributions paid to a Finnish resident are generally taxable only in Finland.
- How is my US 401(k) or IRA taxed once I live in France? — It depends on your citizenship. For a French resident who is not a US citizen or green card holder, the US–France treaty makes 401(k) and Traditional IRA distributions taxable only in France, while US Social Security is taxable only in the US. US citizens living in France are taxed by both countries, and Article 24 of the treaty gives them credits so they are not taxed twice.
- How is my US 401(k) or IRA taxed once I live in Germany? — In Germany, US 401(k) and IRA distributions are generally taxable as 'other income' (Sonstige Einkünfte). Under the US–Germany treaty, private pension distributions paid to a German resident who is not a US citizen are taxable only in Germany. US Social Security paid to a German resident is taxable only in the US.
Landing in the Netherlands, Sweden or Ireland
Box 3 and the 30% ruling, Sweden's ISK and yield tax, Irish split-year relief and deemed disposal.
- I'm Dutch, working in the US — what taxes apply when I move back to the Netherlands? — A Dutch professional returning from the US becomes a Dutch resident taxpayer on worldwide income and assets. US brokerage accounts and most savings fall into Box 3, taxed on a deemed or actual return each year. A 401(k) is generally treated as a pension under the US–Netherlands treaty, and RSUs that vested for US work are allocated between the two countries.
- Can I get the 30% ruling if I'm Dutch and moving back from the US? — Dutch nationality does not by itself exclude you from the 30% ruling. The test is whether you were recruited from abroad, lived more than 150 kilometres from the Dutch border for more than 16 of the 24 months before starting Dutch work, and meet the salary threshold. Many Dutch professionals returning after years in the US can qualify.
- How is my US 401(k) or IRA taxed once I live in the Netherlands? — For a Dutch resident, a US 401(k) or traditional IRA is generally treated as a pension right under the US–Netherlands tax treaty. It is usually kept out of Box 3 while invested, and withdrawals are taxed in the Netherlands as Box 1 income at progressive rates. Roth accounts and lump-sum withdrawals need specific review.
- I'm Swedish, working in the US — what taxes apply when I move back to Sweden? — A Swedish citizen moving back from the US becomes subject to unlimited tax liability in Sweden on worldwide income. US brokerage holdings are taxed at 30% on capital gains and dividends, US funds face an annual standard-income charge, RSUs earned in the US are allocated between the countries, and 401(k) withdrawals are generally taxed in Sweden under the treaty.
- How is my US 401(k) or IRA taxed once I live in Sweden? — Under the US–Sweden tax treaty, pension distributions paid to a Swedish resident are generally taxable in Sweden as earned income. Whether the account is also subject to Sweden's annual yield tax (avkastningsskatt) while invested depends on how the Swedish Tax Agency classifies it, which is why the classification should be confirmed before large balances arrive.
- Can I keep my US brokerage account after moving back to Sweden? — Some US brokers restrict or close accounts once you have a Swedish address, and EU PRIIPs rules usually stop EU residents from buying US-domiciled ETFs. Existing holdings can often be kept or sold, but new purchases may be blocked. Many returning Swedes move to a broker that serves EU residents and rebuild the long-term portfolio inside an ISK.
- I'm Irish, working in the US — what taxes apply when I move back to Ireland? — An Irish professional returning from the US usually becomes Irish resident from the date of arrival under split-year treatment. US-domiciled stocks are taxed at 33% capital gains tax, EU and Irish funds face 41% exit tax and deemed disposal, 401(k) distributions are generally taxed in Ireland under the treaty, and RSUs are allocated by workdays.
- How is my US 401(k) or IRA taxed once I move back to Ireland? — Under the US–Ireland tax treaty, periodic pension payments from a US 401(k) or IRA to an Irish resident are generally taxable in Ireland as income, subject to income tax and USC. Growth inside the plan is generally not taxed annually. Lump sums and Roth accounts need specific review because Irish treatment does not automatically mirror US treatment.
- Is there tax relief for Irish emigrants moving back from the US? — Ireland has no general tax break for returning emigrants, but three reliefs matter: split-year treatment so US earnings before your arrival are not taxed in Ireland, possible SARP relief if your employer assigns you from abroad and you were non-resident for the previous five years, and customs relief on personal belongings you bring home.
The move itself
Currency, the house, Social Security credits, and the order to do it all in.
- I'm a European in the US thinking of moving back — where do I start financially? — Financial repatriation for Europeans depends on two dates: when you stop being a US tax resident and when you start being resident in your home country. Success requires mapping US assets—RSUs, 401(k)s, and property—against the relevant tax treaty, checking your green card's 'long-term resident' status, and sequencing disposals to avoid double taxation.
- When should I convert my dollars to euros when moving back? — You should convert your dollars to euros in stages rather than all at once, starting 6-12 months before your move. This 'dollar-cost averaging' strategy reduces the risk of exchanging your entire life savings during a period of temporary dollar weakness. Avoid timing the market; focus on matching your currency to your future liabilities.
- Should I sell my US house before or after moving back to Europe? — Selling your US home *before* you lose US tax residency is usually better. It allows you to use the full Section 121 exclusion ($250k/$500k of gain tax-free) and avoids FIRPTA withholding (15% of the sale price) that applies to non-resident sellers. Additionally, some European countries may tax the gain if you sell while a resident there.
- Do my US Social Security credits count if I move back to Europe? — Yes, your US Social Security credits count toward your European pension eligibility through 'Totalization Agreements.' If you have at least 6 US credits but fewer than the 40 required for a US pension, the US can count your European work years to help you qualify. Conversely, Europe can count US years to meet their minimums.
- How do I rebuild retirement savings in Europe after years in the US? — Rebuilding a European pension means using employer plans (German bAV, the French PER collectif or company savings plans), local tax-efficient wrappers (the French PER and assurance vie, Finnish PS-sopimus), and, where your country allows it, voluntary contributions to fill gaps in the state system. You should also utilize totalization agreements to ensure your US years count toward your European state pension.
- What's the right order to do everything financially when moving back to Europe from the US? — Success depends on a 12-month sequence: 12 months out, analyze exit tax and choose your 'landing' date. 6 months out, consolidate US accounts and begin currency staging. 3 months out, sell US property and vested RSUs if the tax rate is favorable. In the final month, file Form I-407 and update your address with US banks.