A practical, SEC-compliant guide for foreign nationals moving to the U.S., explaining how foreign assets, pensions, and investments are treated under U.S. tax and reporting rules.
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The first introductory meeting with a financial adviser tends to follow a predictable script. The adviser asks about your goals, your assets, your timeline. You ask about fees, about performance, about the firm’s experience. For most families, that conversation is enough. For a family whose life sits across more than one country, the standard questions don’t go far enough.
In my work with cross-border house holds, the moments things go wrong are almost never the moments an adviser failed at the standard task. They’re the moments the standard task wasn’t the right task to begin with. A US-resident expat couple finds their portfolio holds a PFIC. An American moving abroad discovers their custodian will not keep the account open. A non-citizen spouse learns the marital deduction they assumed protected them does not. The right questions at the start would have surfaced every one of them.
This article sets out ten questions worth asking any cross-border adviser, including any conversation with our team. They’re written for the reader to use, not for any one firm to answer. They group naturally into three: regulation and custody, technical planning capability, and fees, coordination, and continuity.
Most public guidance on choosing an adviser is written for a household that lives, earns, and dies in one tax system. For across-border family, the questions that matter sit one layer deeper than the standard list. They test whether the firm has set itself up, regulatorily, operationally, and technically, to handle the specific complications across-border life produces.
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The first three questions are about whether the firm is structurally able to act for you. Custody and regulation come before strategy, because a strong recommendation that can’t be implemented through the firm’s actual custodian relationships is academic.
A US-registered investment adviser is governed by the Securities and Exchange Commission and SEC Marketing Rule206(4)-1, which sets the standard for what the firm can and cannot say to clients. For a household whose life touches more than one country, registration in additional jurisdictions can also matter, if the firm advises a UK or Swiss resident, for example. A firm that takes this seriously will walk you through where it’s regulated, why, and what each regulator covers.
Custody is the practical bottleneck in cross-border planning. A US custodian may be willing to hold a brokerage account while the client lives in the US but unwilling to keep it open if they move abroad, and that’s true even if the client remains a US citizen. Different custodians take different positions, and those positions change. A firm that takes this seriously will name the custodians it uses, describe which residency profiles each accepts, and explain what happens to your account if your residency changes during the relationship.
The next layer of the custody question. Even within the same custodian, account-level rules differ, what’s allowed fora US-resident account isn’t always allowed for a non-US-resident account at the same firm. The right answer describes a process for checking, in advance of a move, whether the existing structure can travel with the client or whether anew one is needed.
The next four questions test whether the firm has the technical depth to do the work cross-border families need done. Each question maps to an issue that comes up routinely in practice.
A passive foreign investment company (PFIC)is, in plain terms, a non-US pooled investment fund, including most non-US mutual funds, ETFs, and UCITS funds that European and Asian residents typically hold. PFICs trigger a punitive US tax regime that can erase years of investment return for a US-resident or US-citizen investor. A firm that takes this seriously will describe the screen it uses to identify PFICs, the policy it applies when one is found, and how it documents the position for the client’s tax preparer at year-end.
A UK SIPP, a Swiss pillar 2, a German pension, an Irish PRSA, each has a different US tax footprint, and most planning software does not handle any of them out of the box. A firm that takes this seriously will describe how these assets are represented in retirement projections, how FX and growth assumptions are handled, and how the income-tax treatment on withdrawal is modeled. If foreign pensions are rolled into a generic “other” line, the projections aren’t doing the work you need them todo.
Every priority jurisdiction in cross-border practice, the United Kingdom, Ireland, Switzerland, Germany, the Netherlands, France, has a US income tax treaty, an estate tax treaty, or both. The treaties modify the default US rules on residency, retirement income, real estate, and the unified credit available to a non-US-domiciled spouse. A firm that takes this seriously will describe how often it applies the relevant treaty, the cases it sees, and how it coordinates positions with the client’s US and home-country tax preparers.
Most cross-border households need to file at least one foreign-account information return, and many need both FBAR(FinCEN 114) and Form 8938. Neither is filed by the adviser, but the adviser produces the year-end information the tax preparer relies on. A firm that takes this seriously will describe its year-end information packet, how it identifies reportable accounts the client may not have flagged, and how it keeps positions aligned across returns.
The last three questions are about how the relationship works, over years, across countries, and alongside the other professionals in the client’s life. These are the questions most often skipped, and the ones that determine whether the relationship outlasts a relocation.
A fee schedule that looks straightforward when listed in dollars on a US asset base can be harder to read when the relationship sits across multiple jurisdictions. A firm that takes this seriously will tell you, in writing, what the fee covers, what triggers it, what additional fees apply where (custodial, currency-conversion, transactional), and how the fee structure changes if the client moves jurisdictions. The right level of detail is the level at which you can replicate the calculation yourself.
A cross-border household typically retains at least two tax preparers, one in the US and one in the home country, and planning decisions need to land coherently with both. A firm that takes this seriously will describe how year-end information flows from the firm to each preparer, how mid-year decisions (Roth conversions, capital-gain harvesting, foreign-currency transactions) are signposted in advance, and how it handles the case where the two preparers disagree on a position.
Cross-border lives change shape. A firm that takes this seriously will describe how the relationship continues through a relocation, which custodians can travel, which accounts need restructuring, which planning positions need to be revisited. The same firm should be able to describe how it handles estate planning for a mixed-nationality marriage, the unlimited marital deduction issue, the QDOT mechanics, the relevant estate-tax treaty positions, because that conversation comes up in almost every cross-border household.
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A short reference grid for use in adviser conversations. The middle column is what the question is testing. The right column is what a firm taking the question seriously tends to sound like, written in the generic, because it’s the shape of a thoughtful answer that matters, not the wording any one firm would use.
Source: Skybound 2026
The right way to use this article is to put the same ten questions to two or three firms, including any conversation with our team, and listen for whether the answers describe a firm that has set itself up for the work. Skybound Wealth USA welcomes that conversation. To take it forward, book a discovery call with our team.
Beyond the ten questions in this article, the conversations that go best tend to surface a handful of specifics. Considerations to raise include:
A screen the firm runs against client portfolios to identify PFICs, a policy it applies when one is found (substitute, exclude, or accept the reporting burden), and year-end documentation provided to the client’s tax preparer. A firm without a working answer on all three parts is not currently equipped to manage portfolios for US-resident or US-citizen clients.
Heavily, if your residency is likely to change. The custodian determines whether your accounts can stay open after a move, how the assets are reported, and which transactions are operationally possible. Two firms that look identical on paper can produce very different lived experiences depending on which custodial relationships they hold and which residency profiles those custodians accept.
“Dual qualified” is shorthand for an adviser holding regulated status in more than one jurisdiction. There’s no single global standard. What matters is whether the firm, through individual licensing, group structure, or referral relationships, can lawfully advise the client across the jurisdictions the client lives across. The right answer describes the specific arrangements, not a label.
Because they assume one tax system, one custodian relationship, and one set of reporting obligations. A cross-border household has more than one of each. The fee question doesn’t tell you which custodian holds the assets or whether that custodian will keep the account open after a move; the performance question doesn’t tell you whether the portfolio includes PFICs that will be taxed punitively when the client becomes a US resident.
Tom Pewtress is Head of USA at SkyboundWealth USA and a member of the Skybound Wealth Management Executive Committee.A fee-based fiduciary adviser with more than a decade advising internationallymobile households, Tom helps US citizens, dual-nationals, green card holders,and families moving to or from the United States align their wealth, taxposition, and long-term plans across borders.
His work focuses on the issues cross-borderclients actually face: 401(k) and IRA decisions when leaving the US, Rothconversion strategy, tax-aware investing across jurisdictions, PFIC andforeign-fund pitfalls, Social Security totalization, and estate planning forfamilies with ties to more than one country.
Tom regularly writes and speaks oncross-border financial planning. He also leads Skybound's global training andproposition work, ensuring the firm's financial planners remain highlytechnically capable in the industry.
This article is for educational and informational purposes only and does not constitute personalized investment, tax, or legal advice. Tax and regulatory rules change frequently and their application depends on individual circumstances. Readers should consult qualified professionals before making any financial decisions. Skybound Wealth USA is an SEC-registered investment adviser; registration does not imply any level of skill or training.
The right ten questions for a cross-border adviser tend to surface the gaps that domestic-only firms rarely admit to: fiduciary status, jurisdictional licensing, treaty fluency, and PFIC handling.
A short conversation with Tom can give you a clearer picture of where you stand and what is worth acting on first.

An adviser who answers cross-border questions cleanly on the first call is rare. The selection process itself is a useful diagnostic of whether the firm is right for your situation.
Tom Pewtress works with cross-border families to clarify what to look for in an adviser and what gaps to test for in any conversation.

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In a private introductory session, Tom can help you: