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Financial planning for Americans in Basel.
Basel pulled you in for the role — Roche, Novartis, Lonza, Syngenta, Clariant, BIS, or a senior US pharma transfer. The package is excellent. The wrinkles are real. Your Pillar 2 quickly becomes the biggest single asset you'll ever own, and almost every fund inside it is a PFIC. RSUs vest both sides and almost nobody coordinates the tax. Many colleagues commute from Germany or France, which adds a whole third system. We build for Americans at Basel's pharma majors — your US side stays clean, your Swiss side gets done 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
- Pillar 2 funds are PFICs
- Basel-Stadt wealth tax with no US credit
- Roche / Novartis RSUs taxed both sides
- Lump-sum vs lifetime pension at retirement
- Cross-border commuters (DE / FR)
- US brokers closing Swiss-address accounts
Your Pillar 2 quickly becomes the biggest pot you'll ever own here — and almost no one has modelled how the US will tax it
For senior US earners at Roche, Novartis, Lonza, Syngenta, Clariant, the Bank for International Settlements, or any of Basel's mid-market pharma and biotech employers, the 2nd pillar (BVG) often grows into the single largest line on your balance sheet — CHF 500k to CHF 3M+ by mid-career, sometimes much more. The US recognises the pension wrapper under the treaty, but the underlying Swiss collective funds inside are PFICs requiring annual Form 8621. Pillar 2 buy-ins (Einkäufe) are pushed hard at Roche and Novartis for the Swiss tax deduction — they usually give no US relief and quietly deepen the PFIC base. The lump-sum vs lifetime pension choice at retirement is one of the most expensive cross-border decisions of your life.
If your RSUs and PSP vest in Basel, you're in a four-way puzzle most people only see two sides of
Roche's PSP / RSU program and Novartis's RSUs / PSUs vest under Swiss employment rules and are reported on your Lohnausweis. The US wants the same vest on your 1040 with a treaty-based foreign tax credit, sourced workday-by-workday across the grant-to-vest period. Performance multipliers add another sourcing layer. ESPP discounts, sell-to-cover defaults, leaver dates, and whether you're paid in CHF or USD all change the optimal sequence. Doing it in isolation on either side leaves real money on the table every single vest — and there's a vest at Roche and Novartis every quarter.
Basel-Stadt's wealth tax is among the higher cantons — and the US gives you zero credit for it
Basel-Stadt levies an annual cantonal wealth tax on your worldwide net assets. Your investment portfolio, your US brokerage, your crypto, your property equity, your private holdings — all in. The US has no wealth tax and gives no foreign tax credit for it. For a Basel pharma family with CHF 5M+ of net assets, this is real money every year — on top of what the income tax already took. Debt deduction, pension positioning and the location of business equity are the real levers.
The Pillar 2 lump-sum vs lifetime pension decision is the most expensive day of your Swiss retirement — plan it 10 years out
At retirement you can take Pillar 2 as a lump sum, a lifetime pension (Rente), or a mix. Switzerland taxes the lump sum at a preferential separate rate; the Rente is taxed as ordinary income. The US treats the lump sum as a pension distribution but still gets first taxing rights as your citizen, and timing across calendar years can change the answer by six figures. Canton-of-residence at payout (Basel-Stadt vs Basel-Landschaft vs Schwyz) is its own decision. We model both sides over a 10-year horizon.
If you live in Germany (Lörrach, Weil) or France (Saint-Louis) and work in Basel, you've added a third tax system
Many Basel pharma employees commute from Germany or France. The 60-day rule for German Grenzgänger, the French border-worker regime, the Basel cantonal source tax, and where your family is registered all interact. For a US citizen this becomes a three-system problem and the US saving clause still gives the US first taxing rights. We map the actual footprint and your residency before tax-time surprises arrive.
The 3a your Swiss Life or AXA adviser sold you stacks a separate US life-insurance problem on top of PFIC
Insurance-wrapped 3a (Säule 3a Versicherung) at Swiss Life, AXA, Helvetia or Baloise looks like savings to the Swiss side — but to the US side the build-up inside the policy is taxable each year under US life-insurance rules, and the underlying funds are PFICs. Surrender penalties usually lock you in. We see this on most Basel diagnostics and either restructure or stage the unwind across two tax years.
Eigenmietwert is being abolished — and that changes whether you should pay down your Basel mortgage early
Swiss voters approved abolition of the imputed-rental-value tax on primary residences in September 2025, effective from 2028. The traditional Swiss strategy — carry a big mortgage and amortise indirectly through a 3a, deducting the interest against imputed rental — is built on a tax that's about to disappear. For a US person we layer in US currency-gain rules on the CHF mortgage, US mortgage interest limits, and the home-sale exclusion.
UBS doesn't really want you anymore. Your US broker is closing your account too.
On the US side, Schwab, Fidelity, Vanguard, Morgan Stanley and Merrill have all restricted or closed accounts for US persons with a Swiss address. UBS (post-Credit Suisse), Basler Kantonalbank, PostFinance and most cantonal banks have either pushed US persons to high minimums or closed accounts. Interactive Brokers, Schwab International (for qualifying clients) and a small bench of Swiss setups genuinely work — but the migration has to be sequenced around Pillar 2 / 3a / RSU events.
If your spouse isn't a US citizen, your US estate plan probably doesn't protect them
The US federal estate tax applies to US citizens worldwide, but the unlimited marital deduction does not apply if your spouse isn't a US citizen — a QDOT trust is typically required to defer US estate tax at first death. Basel-Stadt and Basel-Landschaft exempt spouses and direct descendants from cantonal inheritance tax. The US–Switzerland estate treaty coordinates the two sides — only if your estate plan was actually drafted with both in mind.
Frequently asked questions
I work at Roche or Novartis. Are my RSUs / PSP / PSUs really a cross-border problem?
Yes. Swiss employment rules tax the vest on the Lohnausweis; the US wants the same vest on the 1040 with a treaty-based foreign tax credit sourced workday-by-workday across grant-to-vest. Performance multipliers add another sourcing layer. Done in isolation on either side, you leave real money on the table every single quarter.
Is my Pillar 2 really a problem if I'm American?
The pension wrapper is recognised by treaty, but the underlying funds inside are PFICs requiring annual Form 8621. The real money is the lump-sum vs lifetime pension decision at retirement — we model both sides 10 years out.
Should I make Pillar 2 buy-ins (Einkäufe) at Roche / Novartis?
Sometimes yes, often no. The Swiss deduction is real; US-side relief is usually nil and the PFIC base deepens. We model the after-tax outcome on both sides before you wire the buy-in.
I have an insurance-wrapped 3a at Swiss Life / AXA. Is that a problem?
Yes, on two fronts: the underlying funds are PFICs and the build-up inside the policy is taxable each year under US life-insurance rules. Surrender penalties usually lock you in. We restructure or stage the unwind across two tax years.
I commute from Germany or France. Does that change anything?
Materially. Grenzgänger rules, French border-worker treatment, the Basel cantonal source tax and where your family is registered all interact. For a US citizen this becomes a three-system problem — and the US saving clause still puts the US first.
What happens with the Eigenmietwert abolition?
Voters approved abolition in September 2025; effective from 2028. Anyone with a Basel mortgage held mainly for tax reasons needs to revisit the strategy now.
My US broker is closing my account because I live in Basel. What do I do?
Move before they force-liquidate. Interactive Brokers, Schwab International and a small number of Swiss-friendly setups genuinely support US persons. We sequence the migration alongside any Pillar 2 / 3a / RSU events.
Do I need a QDOT for my non-US 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. We draft this with a Basel notary and a US estate attorney together.
Do you actually file my US or Swiss taxes?
No, deliberately. We coordinate a US CPA and a Basel Treuhänder 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
Book a Fit Conversation — Complimentary Fit Conversation (45 min).