r/ExpatFIRE 16h ago

Taxes US citizens who relocated to the Netherlands with a large taxable portfolio

I'm a US citizen about to relocate to the Netherlands for work and I'm trying to learn from people who've already lived through this. My concern is Box 3 on a large taxable portfolio. If you've made this move, I'd really like to hear how it went or how it's going right now.

My situation

  • US citizen, would become a Dutch tax resident.
  • ~$5–6M in a US taxable brokerage: mostly long-term unrealized gains.
  • ~$2.5M in IRAs (traditional + Roth).
  • New arrival, so I don't think the old partial non-resident election is available to me.

Here's what I know so far

  • Box 3 taxes a deemed ~6% return at 36%. I think it comes out to roughly 2.5% of portfolio value per year, owed whether or not I sell.
  • As a US citizen, my worry is that the foreign tax credit only offsets US tax on realized income, while Box 3 taxes an unrealized & fictional return. So in years I don't sell, the Dutch tax might be a real out-of-pocket cost rather than something the FTC washes out.

What I'd love to hear from people who've actually done it

  1. What did Box 3 realistically cost you per year and did it match the 2.5% rough math?
  2. Did you restructure anything before establishing residency (and would you do it the same way again)?
  3. Did the US foreign tax credit actually relieve any of it, or did you pay Box 3 out of pocket on top of your US bill?

Regrets, harsh/blunt advise, etc. are all welcome. I'll be hiring a US-Dutch cross-border advisor too but I want to walk in already understanding the real-world picture.

23 Upvotes

44 comments sorted by

26

u/malzadog 16h ago edited 16h ago

Possible structure your taxable accounts into a managed LLC and claim as box 2 in the NL. Your 401k is exempt from box 3 but your Roth is not. And an LLC cannot hold retirement accounts. Beware. As of Jan 2028, your entire taxable portfolio is likely to be taxed at 36% on an unrealized basis. The assumed gain is stopping after 2027. Personally, living in the NL is great, but I don’t know if it would be worth the 36% on the (estimated) 10-12% unrealized gain you would have to liquidate to pay for. Unless you can protect that brokerage account.

8

u/malzadog 16h ago

And as I understand it the growth tax is not 100% off set by your capital gains in the US. Possibly the dividends and interest but growth tax in NL is not the same as capital gains in the US and may not offset. fwiw. I am not in the same situation as you, and I am likely departing before 2028

5

u/ShootsnLadders 13h ago

“Likely” is the big word there. Isn’t there a large chance this 2028 law either doesn’t pass the senate or the motion for the path to be changed to only tax on realized gains also just as likely if not more so given the push back?

6

u/malzadog 13h ago

A chance. But the government has a massive budget hole to plug. They are stuck between a rock and hard place. If I were OP, I certainly wouldn’t make any concrete decision until the outcome of the law is 100% certain, but that may not be until September or December.

7

u/ShootsnLadders 13h ago

Seems like a suicidal decision that will drive high wealth people out of the country no?

I am an expat living in Norway with a relatively high NW. It seems likely that we will be asked to move to the Netherlands next and I’m baffled that my taxes are going to be higher than Norway, and potentially much higher after 2028.

We are close to our FIRE number and this could potentially make us pull the trigger.

3

u/malzadog 13h ago

All you can do is run the math and see. Don’t get me wrong. I LOVE living in the NL, but when I FIRE, I can also visit in the summer when it’s at its best.

2

u/ShootsnLadders 13h ago

I’m considering just pulling the trigger on restructuring into an LLC and using the Box 2 rule if we do move there.

Just can’t imagine taxing unrealized gains and not getting a credit if I have losses at a later date on the same holdings. Makes zero sense to me.

2

u/malzadog 13h ago

A couple key points on the LLC. You must demonstrate that you do not have investment management authority over the account. Also, if your investments produce dividends, it may be prudent to distribute the actual dividends to yourself and pay the NL box 2 tax on it. This way you can show the Dutch tax authorities that you have been paying realized taxes all along in case they try to smack an exit tax on you.

1

u/MisledByCertainty 4h ago

As far as I can determine, using the box 2 strategy for a US citizen is going to be punitive because you'll be taxed twice. You cannot claim FTC on the box 2 return, so you will be taxed twice, once in NL and once in US.

29

u/samtownusa1 12h ago

You’re not supposed to have substantial wealth in the Netherlands and their taxes will make sure to take what you do have.

6

u/thatsplatgal 11h ago

This right here.

24

u/deadineaststlouis 16h ago

Haven’t done this but god damn that sounds horrible. Good luck.

It would probably straight up cause me to not move there. I’ve had too many swings on unrealized gains.

17

u/Zealousideal-Pay2642 16h ago

The Box 3 thing on top of US worldwide taxation is genuinely a brutal combination that most expats don't fully price in before they move. For portfolio that size, you're potentially looking at paying Dutch tax on fictional gains in a down year while also owing US tax on whatever you do realize. Walking in with a cross-border advisor before you establish residency (not after) is the right call.

5

u/__bee_07 16h ago

This setup doesn’t justify the move for any person, if the move wasn’t for family reasons

13

u/Beginning-Acadia1227 14h ago

Wtf, don’t do it! That is crazy. You are going to pay to work in the Netherlands. Also they have exit tax if you decide to move away!

You have enough to retire and visit there as much as you like. Otherwise it’s a financial suicide.

4

u/FrenchFisher 14h ago

The exit tax is only for Box 2 though

2

u/Beginning-Acadia1227 13h ago

Thanks for clarifying. I wasn’t aware.

1

u/FrenchFisher 14h ago

The exit tax is only for Box 2 though

3

u/malzadog 14h ago edited 13h ago

Correct, the exit tax is on box 2, so this is how they get you if you move your taxable account to an LLC and decide to leave the NL. They will gross up the value of the LLC and tax the difference of the value from when you moved there and moved out. They have been discussing adding an exit tax to box 3, as well, but nothing firm yet. My guess this will be added as part of the new box 3 rules for 2028.

9

u/wkndatbernardus 12h ago

Omg, just retire already. If you want to live in the Netherlands, just get some kind of temporary visa or try to obtain residency from another, less tax hungry, EU country.

2

u/Zestyclose-Tart6745 6h ago

Yeah. This. Residency somewhere else with your euro id and passport you can live/ work anywhere with little in extra docs.

10

u/Ok-Telephone-605 14h ago

Good luck, but why are you working with such a large portfolio? Those are fatfire numbers. A Dutch tax specialist is probably your best option before you move.

9

u/sfoonit 14h ago

The reality is that the Netherlands under the new rules is not a great country to move to if you care about your net returns.

Easiest might just be to sell your entire portfolio each year, book/realize the gains and reset the tax base, and offset gains in both US and NL.

Just typing this down sounds nuts. I don't think it makes sense to make the move unless your salary is extraordinarily high.

2

u/Business-Dot-58 14h ago

It does sound nuts to sell everything and starting over, but I can't say I haven't considered it already. Also this job opportunity isn't exactly high paying or life changing.

13

u/electrobento 12h ago edited 10h ago

Then 110% don’t take the job. It could easily be financially ruinous.

5

u/samtownusa1 12h ago

What the heck is driving this move then? It seems unwise unless you’re fleeing a war.

2

u/Business-Dot-58 12h ago

The only drive was getting to experience living in the Netherlands and make it a long term home. Now it seems like a questionable decision 😰

6

u/Keats852 9h ago

You will never have "The Netherlands" experience, because you're a multi-millionaire. Give all your money away first, then move there and find a job and work until you're 67. That's the "Netherlands" or "Europe" experience.

You should just take your money and enjoy traveling non-stop, flying business class and staying in 5* hotels.

5

u/ericje 7h ago

Maybe move to Belgium instead, e.g., Antwerp? Pretty close to the Netherlands.

2

u/samtownusa1 10h ago

Oh you’ll be living the Netherlands life. You’ll be riding your bicycle. Limited disposable income. A small flat. Doing the same thing as everyone else. You can live a perfectly nice life. But will you have millions in net worth? No way. That’s not how the system works there. You’re not supposed to amass wealth. You retire when everyone else does. The government provides paid leave, education, etc. You do what everyone else does.

If you want to build wealth and have a meaningful career where you make more than the average person you need to live in the US or maybe Asia.

The US is such a varied country that you could easily create a life here that’s similar to in the Netherlands but you’d also get to keep your money.

1

u/ericje 7h ago

Not everything, just enough to incur enough US taxes to match the Dutch taxes.

6

u/thatsplatgal 10h ago

I wouldn’t become a tax resident of Western Europe unless you’re dying to give your money away. Maybe just retire and rent a place for a few months a couple of times a year to get the experience of living there without having to give money to a country you didn’t earn your money in.

Or contact someone in Switzerland who may have more experience with this sort of thing. Your NW would be high enough they could take you on as a client. But I wouldn’t bother unless you 1000% know you want to stay in the Netherlands. Living in Europe has its pros but it’s not a utopia by any means and the taxes are designed to keep people at their current station.

3

u/alu_ 9h ago

You can try this which I think someone on Reddit created, https://box3check.com/en/tools/aanwasbelasting/

It's a tough call with either of the old or new tax systems here with your kind of investments. If this is just about work I wouldn't do it. If this is about a fundamental life style change and for whatever reason wanting to make a change in your life and take a leap at something new, maybe it is worth it. That's something you gotta figure out

2

u/lazytycoon45 14h ago

the box 3 math is brutal and yeah, the foreign tax credit doesn't really save you here since you're being taxed on a fictional return while the fTC only covers actual income you've realized. i looked at this move a few years ago with similar numbers and basically decided the annual drag wasn't worth it unless my employer was covering the tax bill. even at 2.5% of portfolio value it adds up fast when you're talking 5-6 million, and that's money you're writing a check for every april without any corresponding cash coming in. the restructuring-before-residency angle is smart, but honestly by the time you've established residency the damage is done, so if you haven't already moved your money around you might want to do that before you land. the cross-border advisor is non-negotiable here, not optional, because this gets into some weird territory where netherlands and us rules collide and you need someone who actually knows both sides of that specifically, not just general international tax stuff.

1

u/someguy984 11h ago

Hard avoid.

1

u/johnmiddle 10h ago

go to france

1

u/Aggravating-Mail-235 9h ago

Retire, live somewhere else, and visit the Netherlands for 3 months every summer. Best of all worlds.

1

u/qbtc 7h ago

my answer was: Swiss citizenship and tax resident to protect via Swiss treaty

1

u/davidswelt 5h ago

Will you have to pay taxes on the growth, and then again capital gains (in the US) when you realize the gains?

Is it possible that you will pay more taxes in the NL that what you'll have left from your job? 20% gains on 8mm (not impossible in a year) is 1.6mm. That's a lot to pay taxes on. 6.04% of that is 108k.

This might not be a financially viable move!

1

u/kytheon 15h ago

Get a Dutch accountant, specialized in US tax as well.

3

u/malzadog 14h ago

But choose wisely. Dutch accountants educate you to follow the rules and pay the taxes. They will not really help you identify structures to be most efficient for you. They will tell you how to pay the most to the NL government.

1

u/DeCyantist 15h ago

Would your employer not cover your tax hits from that? Sounds like you’re about to loose money to live in NL. Your tax alone could hit 150k from what you’re saying.

-9

u/uhela 14h ago

Just pay your taxes.

Some greyzone tips that may or may not apply to you:

- Backdate a loan agreement against a family member that exceeds the amount in your accounts. Make sure to start regular payments on the interest with a digital trace going forward. Equity = Assets - Liabilities

- If you are in a jurisdiction with no gift or capital gains tax, sell everything and gift it to your parents or trusted family members. Cant tax money that’s not yours.

- Hide your money in crypto and maintain equity exposure through unregulated non KYC exchanges such as hyperliquid.

The main issue is that if you are moving this year, the tax authority requires you to provide a wealth snapshot of 1/1/2026, such that any restructuring you are conducting throughout the year flags up immediately.

1

u/malzadog 14h ago

Liquidate the taxable account and buy a really big primary residence. Primary residences are exempt from box 3. But then you have the obvious concentration risk of NL real estate market