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

Most Americans in Sweden come for a role at Spotify, Klarna, Ericsson or a Nordic HQ, or for a Swedish spouse and a quieter life. The dream is usually specific: an apartment in Södermalm or Östermalm, and a sommarstuga somewhere in the Stockholm archipelago for July. The money side is what quietly undoes it — an ISK taxed one way in Sweden and another way entirely by the IRS, a pension system with its own pillars, and a US broker that gets nervous the moment your address changes.

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

ISK/kapitalförsäkring taxed as PFICs by the IRS
401(k)/IRA under the US–Sweden treaty
Swedish pension pillars vs your 401(k)
Expert tax relief and the US recapture
Bostadsrätt mortgage currency risk
No Swedish inheritance tax, full US estate tax

Your ISK is taxed simply in Sweden and expensively in the US

Sweden taxes the ISK each year on a flat schablonintäkt regardless of performance. The IRS ignores that wrapper and looks straight through to what's inside — and almost every Swedish or European fund held in an ISK is a Passive Foreign Investment Company for US tax purposes, triggering Form 8621 and a punitive default tax on gains the Swedish side never flagged.

The insurance wrapper your bank suggests adds a layer the IRS doesn't recognise

A kapitalförsäkring is taxed almost identically to an ISK in Sweden, so it's marketed as interchangeable. For a US citizen it isn't: depending on structure, the IRS can treat it as a foreign grantor trust, adding Forms 3520 and 3520-A on top of whatever PFIC funds sit inside.

Tjänstepension and premiepension are treaty-protected — the funds inside them often aren't

The US–Sweden treaty's pension article generally governs how a Swedish occupational or state pension is taxed on distribution. It says nothing about the default fund menu inside the premiepension or your employer's tjänstepension plan, which is frequently built from the same PFIC funds as everywhere else in Sweden.

Your 401(k) can stay invested — but the Roth question needs a real answer

Under the treaty, pension distributions are generally taxed where you live, so a 401(k) or traditional IRA withdrawal is usually Swedish-taxable with a US credit available. A Roth is murkier: Sweden has no domestic concept of a tax-free retirement account, and nothing guarantees Sweden will treat a Roth withdrawal the way the US does.

Expertskattelättnad can cut your Swedish tax — and hand some of it straight to the IRS

Qualifying experts, researchers and high earners get 25% of employment income exempt from Swedish tax for up to five years, with a three-month application window from the start of employment. Less Swedish tax paid usually means fewer foreign tax credits to offset US tax on the same income, so the real net benefit is smaller than the headline number.

A bostadsrätt in Stockholm, or a sommarstuga in the archipelago, is a US currency decision too

A krona-denominated mortgage can create a taxable US exchange gain on refinancing or repayment even when nothing was earned economically, and the Swedish uppskov deferral on a home sale gain has no US mirror. Buy the sommarstuga — just model the mortgage and the eventual sale on both sides first.

Sweden abolished inheritance tax in 2005. The US didn't abolish anything.

Arvsskatt and gåvoskatt are gone for Sweden entirely. The US still taxes the worldwide estate of its citizens and domiciliaries, and a non-US-citizen Swedish spouse inheriting US-connected assets doesn't get the unlimited marital deduction automatically. Families who've lived in Sweden for years sometimes stop estate planning altogether because Sweden charges nothing — the US side keeps running regardless.

The treaty and the totalization agreement both genuinely help — if claimed properly

The 1994 treaty (amended 2005) and the 1987 Social Security agreement reduce real double taxation on pensions, dividends and payroll contributions. Neither applies itself — a certificate of coverage has to be requested, and treaty articles have to be claimed on the US return, not assumed.

Frequently asked questions

Is my ISK really a problem for US tax purposes?

The ISK wrapper itself isn't a PFIC, but almost everything commonly held inside one — Swedish and European funds — is. That triggers Form 8621 and punitive default US tax on gains Sweden taxes completely differently.

Is a kapitalförsäkring any safer than an ISK?

Not generally. It's taxed the same way in Sweden but adds a foreign insurance-wrapper layer the IRS can treat as a foreign trust, with its own reporting on top of any PFIC funds inside.

What happens to my 401(k) and IRA if I move to Sweden?

They can generally stay invested. Under the US–Sweden treaty, distributions are typically taxed where you live, with a US credit available. Roth withdrawals need a deliberate, documented Swedish position rather than an assumption of tax-free treatment.

Can I use the Swedish expert tax relief as an American?

Yes, if you qualify by role or salary level. Twenty-five percent of qualifying income is exempt from Swedish tax for up to five years, applied for within three months of starting work — but part of the saving is typically recaptured by the IRS through a reduced foreign tax credit.

Does Sweden's lack of inheritance tax mean my family avoids estate tax entirely?

No. Sweden abolished inheritance and gift tax from 2005, but the US still taxes the worldwide estate of its citizens and domiciliaries. A non-US-citizen Swedish spouse doesn't get the unlimited marital deduction automatically.

Do you file my taxes?

No. We coordinate a US CPA and a Swedish 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

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