DiscoverThe Expat Sage PodcastThe U.S.–Swiss Financial Double Lock Explained
The U.S.–Swiss Financial Double Lock Explained

The U.S.–Swiss Financial Double Lock Explained

Update: 2025-12-12
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It’s not a glitch. It’s the system. When U.S. citizenship-based taxation meets Switzerland’s residence-based rules, the result is a financial double lock that touches every account, fund, pension, and estate plan. We unpack how FATCA hardened bank compliance, why neo-banks shut out U.S. clients, and how the shift to a Model IGA will make transparency automatic and unavoidable. Then we map the roadblocks that turn simple investing into a maze: PFIC rules that punish European funds, and Swiss KID requirements that block U.S.-domiciled ETFs from retail sale.

We get practical about solutions, not just problems. Learn how Interactive Brokers enables execution-only access to U.S. ETFs, when qualifying as a professional client lifts the KID barrier, and where the options assignment method can lawfully place shares in your account without a direct sale. We weigh the costs and risks of direct indexing with individual stocks, showing how to stay PFIC-free without surrendering diversification. Along the way, we explain the hidden traps in the Swiss three-pillar system—phantom income on Pillar 2 contributions and PFIC landmines inside many Pillar 3A products—even after the trust-reporting relief of 2020.

Finally, we zoom out to the lifetime tax picture: limited foreign tax credits, non-creditable Swiss wealth tax, and the harsh contrast on capital gains where Swiss neighbors pay zero while Americans owe U.S. tax with no offset. We close with the estate tax sting that many expats underestimate. Our playbook is clear: accept compliant banking costs, stick to U.S.-domiciled ETFs via execution-only routes or build with individual stocks, keep Pillar 3A in cash or guarantees. Subscribe, share this with a friend in Switzerland, and tell us: which part of the double lock hits you hardest?

For detailed information read the book Investing from Switzerland, a Comprehensive Analysis of Cross-Border Wealth Management for U.S. Persons Domiciled in Switzerland.

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The U.S.–Swiss Financial Double Lock Explained

The U.S.–Swiss Financial Double Lock Explained

The Expat Sage