Financial planning for Americans living, working or retiring in Denmark.

Most Americans in Denmark didn't move for a spreadsheet. They moved for a Copenhagen flat near Østerbro or Frederiksberg, a cargo bike instead of a second car, a research post at Novo Nordisk, Maersk, Ørsted or DTU, and — if things go well — a sommerhus in North Zealand within a few years. Then the Danish system arrives. Lagerbeskatning taxes most funds every year whether you sold anything or not. The aktiesparekonto your bank opened for you is a PFIC underneath. The researcher tax scheme that looked like a windfall can quietly shift more tax to the IRS. And nobody is reconciling your 1040, your Danish årsopgørelse and the US–Denmark treaty so the numbers actually agree. We're built specifically for US-connected families in Denmark, so the life you moved for doesn't get taxed twice.

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 2026-10-09.

Key issues

Lagerbeskatning on unrealised fund gains
Aktiesparekonto & Danish funds as PFICs
Forskerordningen vs US foreign tax credit
401(k)/IRA under the US–Denmark treaty
Danish pensions (ratepension/livrente)
Boafgift with no US estate tax treaty

Denmark taxes most of your funds every year, whether you sold anything or not

Lagerbeskatning — the mark-to-market principle — taxes most investment funds and the aktiesparekonto annually on the change in value over the year. The US generally waits until you sell. That mismatch means a Danish tax bill can land in a year the IRS sees no taxable event at all, with no US credit to offset it that year. On top of that, the same non-US fund is almost always a PFIC under US law, so the exposure is layered, not single.

The account your Danish bank recommended is a PFIC wrapper with no US shelter

The aktiesparekonto is a genuinely good account for a Dane — a flat rate on a capped deposit, taxed under lagerbeskatning. For a US citizen it has no recognition in the tax code at all. If it holds pooled funds rather than individual shares, you're looking at Form 8621 per holding and a Danish flat rate that often doesn't convert cleanly into a US foreign tax credit.

Danish investeringsforeninger and UCITS ETFs are PFICs — Form 8621, every holding, every year

Danske Bank, Nordea and Nykredit will default you into Danish or Luxembourg-domiciled index trackers that look identical to a US S&P 500 fund. They are not equivalent under US law. Without a timely qualified electing fund or mark-to-market election — which generally cannot be made retroactively — the default PFIC regime can tax gains far more heavily than ordinary US capital gains rates.

The researcher tax scheme's flat rate can quietly shift tax from Denmark to the IRS

Forskerordningen lets qualifying researchers and highly paid key employees elect a flat 32.84% on gross salary for up to 7 years instead of ordinary progressive Danish tax. It's a real, attractive Danish mechanism — but it only changes the Danish side. A lower Danish bill generates a smaller foreign tax credit, which can mean more US tax due overall on the same salary. We model the after-US-tax result before you elect, not after.

Your 401(k), IRA and Roth can stay invested — but the treaty position has to be claimed, not assumed

The US–Denmark treaty generally supports deferral treatment for a qualifying 401(k) or IRA, with Denmark taxing distributions as income when taken rather than the balance annually. That protection isn't automatic — it has to be documented and argued with your Danish adviser. Roth treatment is less settled, and a self-directed IRA's underlying holdings still need checking for PFIC exposure.

Your ratepension or livrente is valuable — and the fund menu inside it is still the PFIC problem

Danish workplace pensions defer tax on contributions and growth until payout, and employer contributions are real money worth keeping. The US–Denmark treaty generally supports similar deferral for a US citizen, but that's a position taken on the US return, not an automatic exemption — and the pooled funds most Danish providers invest in are typically PFICs regardless of the pension wrapper around them.

A sommerhus in North Zealand, or a kept US rental, both enter a second tax system

Once Danish resident, worldwide income — including a US rental property you kept — is reportable in Denmark, with a credit intended to prevent double taxation. A Danish home separately enters the ejendomsværdiskat system, assessed on the property's value, often on a provisional valuation with a later true-up. A kroner mortgage can also create a US currency question on refinancing if the dollar has moved.

Boafgift taxes the estate; the US taxes what you leave — with no treaty bridging the two

Denmark charges boafgift at 15% above an annual allowance, with spouses exempt, plus a 25% supplement for beneficiaries outside the close family. There is no comprehensive US–Denmark estate tax treaty, so Danish boafgift and US estate tax can both apply to the same assets. A US citizen married to a Danish national also needs a QDOT — without one, the usual unlimited US marital deduction doesn't apply.

Frequently asked questions

What is lagerbeskatning and does it really apply to my funds?

Lagerbeskatning is Denmark's mark-to-market tax principle: most investment funds and the aktiesparekonto are taxed annually on the change in value, whether or not you sold anything. For a US citizen it generally stacks on top of PFIC exposure on the same fund rather than replacing it.

Should I use the aktiesparekonto my Danish bank opened for me?

Usually not, if it holds pooled funds. The account is genuinely good for a Dane, but it has no US recognition, and the funds inside are typically PFICs, which adds Form 8621 reporting without a matching US benefit.

I'm on forskerordningen — is the flat rate actually a win?

It's a real Danish advantage, but it only changes the Danish side. A lower Danish bill generates a smaller US foreign tax credit, which can mean more US tax due overall. We model the after-US-tax outcome before you elect.

What happens to my 401(k) and IRA in Denmark?

They can generally stay invested, with the US–Denmark treaty supporting deferral treatment so Denmark taxes distributions as income when taken rather than the balance annually. That protection needs to be documented and claimed, not assumed — and Roth treatment is less settled.

Is my Danish ratepension or livrente a US tax problem?

The wrapper generally gets treaty-supported deferral treatment similar to Danish tax rules, but that has to be claimed on the US return. The pooled funds most providers invest in are typically PFICs regardless of the pension wrapper, which is a separate issue to address.

Do my heirs pay Danish inheritance tax (boafgift)?

Denmark charges boafgift at 15% above an annual allowance, with spouses exempt, plus a 25% supplement for non-close relatives. There's no comprehensive US–Denmark estate tax treaty, so Danish boafgift and US estate tax can both apply to the same assets without full coordination.

Do you file my taxes?

No. We coordinate a US CPA and a Danish tax adviser around one strategy. Keeping advice separate from filing keeps everyone independent.

What does it cost?

A 45-minute Complimentary Fit Conversation at no charge. Planning engagements start at $3,000, with ongoing management on a tiered fee from 1.00% on the first $1M, falling to 0.30% above $10M. No commissions, no product revenue.

Fees

One Private Wealth Management relationship, with Blueprint ($3,000) and Life ($8,000) as planning entry points. Blueprint is complimentary at $1M+ managed by Selanis; Life at $2M+. Ongoing management uses 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).