For people relocating from Switzerland to the United States

Moving to the US From Switzerland: Your First US Tax Year

Relocating from Switzerland? The US decides tax residence by its own tests, your first year is usually split in two, and the US-Switzerland treaty settles dual residence. Here is how each piece works.

Substantial presenceGreen card testDual-status yearTie-breakerSocial security

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Quick answer

When does someone moving from Switzerland start paying US tax on worldwide income?

From the residency starting date: the first day in the US in a year you meet the substantial presence test, or the first day as a permanent resident under the green card test (IRS Pub 519). Before that you are a nonresident, so the first year is usually dual-status. If you are also resident in Switzerland, Article 4 (Resident) of the treaty decides which country you are resident in for treaty purposes.

Prepared by Illuminous Accounting · Sources checked November 11, 2026

At a glance

When you become US resident: Green card test or substantial presence test (Code section 7701(b))
First year: Usually dual-status: nonresident, then resident
Treaty tie-breaker: Article 4 (Resident)
Social security agreement: Yes, since November 1, 1980
Accounts in Switzerland: FBAR, Form 8938 and PFIC rules can apply once resident

Arriving from Switzerland: which test applies

There is no form that makes you a US tax resident. It happens automatically under Code section 7701(b) once you pass either test (IRS Pub 519). A green card does it from the first day you are in the US with permanent resident status. Without one, the substantial presence test does it once you have 31 days this year and 183 weighted days over three years.

Someone arriving from Switzerland with no earlier US days needs to arrive by early July and stay for the rest of the year to pass the substantial presence test in the first year. The calculator shows the date for your arrival.

Your dual-status first year

Your first US year is usually split. Before your residency starting date you are a nonresident, taxed only on US income; from that date you are a resident, taxed on worldwide income, including anything earned in Switzerland after the date. This is a dual-status year (IRS Pub 519).

Under the substantial presence test, the starting date is generally your first day in the US that year; up to 10 days can be ignored if you kept a closer connection and tax home abroad.
Under the green card test, it is the first day you are in the US as a permanent resident.
If you arrive late in the year and miss both tests, the first-year choice can let you be treated as resident for part of it: 31 days in a row in the US and presence on 75% of the days from then to year end, and you must meet the substantial presence test the following year.

Resident in both countries: the US-Switzerland treaty tie-breaker

During the move you can be resident in both Switzerland and the US under each country's law. Article 4 (Resident) of the treaty has the tie-breaker for someone resident in both countries: it looks first at where you have a permanent home available, then at the further tests the article lists, in the order it sets them. If the treaty makes you a resident of Switzerland, you can be taxed as a nonresident of the US for the treaty's purposes, but that position must be disclosed on Form 8833 under Treas. Reg. section 301.7701(b)-7 (IRS Form 8833).

Green card holders should be careful: a long-term resident who claims treaty residence abroad this way may be treated as having expatriated under section 877A (IRS).

Accounts left in Switzerland

Keeping a Swiss bank account or pension after the move is normal, but from your residency starting date the US wants to know about it. The reports are the FBAR, Form 8938 and, for many non-US funds, the PFIC rules on Form 8621 (IRS). Thresholds and deadlines: FBAR and FATCA, Form 8938.

Sources for moving from Switzerland

Treaty

The IRS lists the 1996 income tax treaty, signed October 2, 1996, amended by a protocol signed September 23, 2009. General effective date (IRS Table 3): treaty Jan. 1, 1998; protocol Jan. 1, 2020 (IRS treaty documents for Switzerland; treaty text; IRS Table 3).
Residence and tie-breaker: Article 4 (Resident).
Saving clause: paragraph 2 of Article 1 (Personal Scope).
Article 18 (Pensions and Annuities) and Article 19 (Government Service and Social Security), pensions.
Article 23 (Relief from Double Taxation), relief from double taxation.
Article 15 (Dependent Personal Services), employment income.

US law

US residency tests and starting dates: Code section 7701(b) (IRS Pub 519).
Treaty residence for dual residents: Treas. Reg. section 301.7701(b)-7, Form 8833 and section 6114; long-term residents: section 877A (IRS Form 8833).
Social security agreements: SSA list.

The rules of Switzerland on leaving the country also apply; check them with a local adviser.

How we help

Gurleen Kaur, CPA licensed in British Columbia and Washington State, prepares the first-year dual-status return, treaty disclosures and the reporting for accounts left in Switzerland. Every engagement starts with a written quote after we review your dates and income. Also see Form 1040-NR.

Moving from other countries

All countries: moving to the US, by country. From Canada: moving from Canada to the US.

Common questions

Am I a US tax resident in my first year after leaving Switzerland?

When you meet the green card test or the substantial presence test (31 days this year and 183 weighted days over three years). Your residency starting date is generally your first day in the US that year, or your first day as a permanent resident.

What if I am resident in both Switzerland and the US?

Article 4 (Resident) of the treaty breaks the tie, starting with where you have a permanent home. Claiming treaty residence in Switzerland on a US return needs Form 8833.

Do I report my accounts in Switzerland after moving to the US?

Once you are a US resident, yes: the FBAR when foreign accounts total more than US$10,000, Form 8938 above higher thresholds, and PFIC rules for many foreign funds.

Is there a US social security agreement with Switzerland?

Yes, in force since November 1, 1980.

Sources

Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.

Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated November 11, 2026. This page is general information, not tax or legal advice for your situation.

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