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Financial planning for Americans in Amsterdam.
Amsterdam pulled you in for the role — Uber, Netflix, Booking, Adyen, an EU regional HQ or a tech transfer from the US. The package is generous. The cross-border wrinkles are real. The 30% ruling is your single most valuable benefit and the rules just changed. Box 3 taxes a deemed return on your wealth, even if your portfolio lost money. Your US broker is nervous about your Jordaan address. We build for Americans on Dutch payroll in Amsterdam — your US side stays clean, your Dutch side gets filed properly.
Cross-border financial planning and US investment management for Americans living abroad, typically with $1M+. Most clients have $1M+ in investable assets; we also work with selected households from $500K.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-06-30.
Key issues
- 30% ruling: new 30-20-10 schedule
- Box 3 wealth tax on deemed returns
- RSUs taxed both sides without coordination
- Dutch pension funds inside RSU-style awards
- US brokers closing EU-address accounts
- PFICs in any Dutch beleggingsfonds / lijfrente
The 30% ruling is your single biggest benefit — and the rules quietly changed in 2024 and 2027
The 30% ruling exempts up to 30% of your Dutch employment income from income tax for qualifying highly-skilled migrants, and historically also let you elect 'partial non-resident' status (no Dutch tax on Box 2 and Box 3 worldwide). Three big shifts: (1) the partial non-resident election was abolished for new arrivals from 1 January 2025 (with transitional grandfathering for some 2024 holders); (2) the benefit is capped at the WNT salary norm; (3) the 30-20-10 schedule (30% for years 1–20 of months, 20% for the next 20 months, 10% for the final 20 months — previously planned, now revised back to 30% for the full 5 years under the 2025 reversal). We model where you actually sit under the current rules, including the partial-resident grandfathering and the 8-year benefit window, before any payroll change is made.
Box 3 taxes a deemed return on your wealth — even if your portfolio lost money — and the system is being rewritten by 2027
Box 3 doesn't tax your actual return. It applies a deemed return to your worldwide net assets (savings, investments, second property, crypto, business interests held passively) above a small exemption — and then taxes that deemed return at ~36%. The 2021 Hoge Raad Christmas judgment ruled the old flat-rate system unlawful for over-assessed taxpayers; a transitional law applied differentiated deemed returns for savings vs investments. A full actual-return system is targeted for 2027–2028. For a US person, none of this is creditable against your 1040 — there's no underlying realised income for the IRS to credit. Asset location, debt netting, the partial-resident election (where grandfathered), and whether to hold investment property personally or through a BV are the real levers.
Your RSUs vest in Amsterdam. The Netherlands taxes the vest at marginal rates. The US already taxed it as wages.
The Netherlands taxes RSU vesting as Box 1 employment income at marginal rates up to ~49.5%. The 30% ruling can reduce the taxable share. The US has typically already withheld at vest as wages. Without a workday sourcing analysis between US and Dutch service periods, a treaty-based foreign tax credit and timing of sales aligned with FX and bracket, you genuinely pay both. PSU performance multipliers and the Uber / Booking / Netflix grant-clawback rules add another sourcing layer.
Your Dutch pension contributions look like a deduction in NL — and a US PFIC problem if structured wrong
Dutch occupational pension contributions to qualifying schemes are deductible in NL, and the US–Netherlands treaty (Article 19) gives meaningful pension coordination for some structures. But individual lijfrente products and any beleggingsfonds inside a deferred wrapper can be PFICs requiring Form 8621. The 'lump-sum at retirement' option introduced by the 2023 pension reform (Wet toekomst pensioenen / WTP) is a major US-side decision point we model years out, not at retirement.
If you set up a BV in the Netherlands, you've created a foreign corporation the IRS sees very differently
Founders, contractors and senior consultants are often pushed toward a BV (private limited company) and the DGA (director-major shareholder) status. The Dutch side gives clear tax structure; the US side often gives you a CFC / GILTI problem under Subpart F, Form 5471 every year, and a complicated check-the-box election that needs to be made on day one or it's much harder later. Box 2 income (substantial-interest dividends) and the customary salary rule add further interaction. This is a US-side decision wearing Dutch-side clothes.
Your ABN AMRO, ING or Rabobank private banker will pitch a beleggingsfonds. For an American, every one is a PFIC.
Dutch beleggingsfondsen, mixed funds inside lijfrente products, and Luxembourg / Ireland-domiciled UCITS funds your banker frames as 'tax-efficient' are all PFICs for a US person. Form 8621 required, default IRS treatment can produce a US tax bill larger than the gain. Stay US-domiciled, full stop.
Schwab, Fidelity and Vanguard are restricting US persons with Dutch residential addresses
Most US custodians now restrict or close accounts with EU addresses. A forced US-side liquidation crystallises an unplanned tax year and an EUR/USD event. Interactive Brokers, Schwab International (for qualifying clients), and a small number of NL-friendly setups genuinely work. The migration has to be sequenced — usually before you change your address with the IRS, your custodian, or your employer's payroll.
Your Roth is tax-free in the US. The Netherlands doesn't necessarily honour that.
The US–Netherlands treaty gives meaningful pension coordination, but Roth treatment in the Netherlands is unsettled and conservative practice can treat the wrapper as a Box 3 asset on net value. Whether to draw your Roth before your move, after, or convert in a final US-resident window is one of the highest-value decisions for any American planning to stay in NL long-term.
Dutch inheritance tax (erfbelasting) hits your kids; the US estate tax hits your spouse if they're not American
Dutch erfbelasting applies based on the deceased's residency and the relationship to the heir, with reduced rates and exemptions for spouses and children. The US estate tax applies to US citizens worldwide. If your spouse isn't a US citizen, the unlimited marital deduction does not apply and a QDOT trust is typically required to defer the tax at first death. There is no full US–Netherlands estate tax treaty covering the personal-estate side of these issues — coordination has to be drafted into the structure.
Frequently asked questions
Does the 30% ruling still exist after the 2024 / 2025 changes?
Yes. The 5-year duration is preserved, the WNT salary cap applies, and after the 2025 reversal the benefit stays at 30% for the full 5 years for new applicants. The partial non-resident election was abolished for new arrivals from 1 January 2025, with transitional grandfathering for some 2024 holders. We model where you actually sit under the current rules.
What is Box 3 and why does it matter for me as an American?
Box 3 taxes a deemed return on your worldwide net assets at ~36%, regardless of your actual return. The US has no equivalent and gives no foreign tax credit on a deemed return with no realised US income. Asset location, debt netting and (for some structures) the BV alternative are the real levers. A full actual-return system is targeted for 2027–2028 — we plan for the transition now.
How are my Uber / Booking / Netflix RSUs taxed in Amsterdam?
Box 1 employment income at marginal rates up to ~49.5%, with the 30% ruling reducing the taxable share. The US has typically already withheld at vest as wages. Without a workday sourcing analysis between US and Dutch service periods and a treaty FTC, you pay both.
Should I set up a BV?
Sometimes — but it's a US-side decision wearing Dutch-side clothes. A Dutch BV is a CFC for a US person, generating Subpart F / GILTI exposure and an annual Form 5471. The check-the-box election needs to be made on day one. We model the after-US-tax outcome before any incorporation.
What happens to my Schwab or Fidelity account when I move?
Most US custodians now restrict or close accounts with EU addresses. Move before they force-liquidate. Interactive Brokers and Schwab International (for qualifying clients) work. Sequencing matters — usually before you change your address with the IRS.
Should I let ABN AMRO or ING put me into a beleggingsfonds?
Avoid Dutch beleggingsfondsen, mixed funds inside lijfrente products, and the Luxembourg / Ireland-domiciled UCITS your banker frames as 'tax-efficient' — each one is a PFIC for a US person. Stay US-domiciled in an NL-friendly custodian.
What about my Roth IRA in the Netherlands?
Roth treatment in NL is unsettled and conservative practice can treat the wrapper as a Box 3 asset on net value. Whether to draw before your move, after, or convert in a final US-resident window is one of the highest-value decisions on the table.
Do I need a QDOT for my Dutch spouse?
If your spouse isn't a US citizen, the unlimited marital deduction doesn't apply for US federal estate tax. A QDOT is the standard structure to defer the tax at first death. There's no full US–Netherlands estate tax treaty on the personal-estate side, so this gets drafted into the structure.
Do you actually file my US or Dutch taxes?
No, deliberately. We coordinate a US CPA and a Dutch belastingadviseur into one strategy. Keeping tax prep separate from advice keeps everyone independent.
What does engagement cost?
We start with a 45-minute Complimentary Fit Conversation. Engagement starts at $3,000 for a focused planning project, with ongoing management on a tiered fee from 1.00% on the first $1M, falling to 0.30% above $10M. No commissions, no retros, no product revenue. Ever.
Fees
Blueprint $3,000 and Life $8,000 (flat planning fees). Private Wealth Management on a tiered, blended schedule starting at 1.00% on the first $1M and declining to 0.30% above $10M. Fee-only: no commissions, no product payments, no lock-in. All fees
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