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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A client I worked with in Singapore took the phone call in early January. Her employer wanted her back in New York by July. Her first instinct, completely reasonable, was to start packing. The instinct that takes longer to arrive is that the six months before her flight would decide more of her US tax picture than the twelve months after it. Returning to the United States isn't simply the reverse of leaving it.
This article explains what I see matter most in the six months before an American repatriates, regardless of the country of return. It is written for US citizens and green card holders who have spent five or more years overseas and are now planning a return. The framework is sequencing, in three phases: decisions made before the plane ticket, decisions that shape the tax year of return, and decisions that land in the first year back. The comparison table is organized by asset archetype rather than by country, because the patterns on re-entry look similar whether the reader is coming from Zurich, London, Dubai, Singapore or Tokyo.
The instinct to wait until the US return is official and then sit down with a US adviser is understandable. It's also the single biggest missed opportunity I see. Many of the questions worth raising, a foreign pension lump sum, a sale of a foreign home, a foreign-fund holding, state residency, sit in the window when the reader is still a non-resident for US tax purposes. Once US residency restarts, the rules change.
Three decisions come up most often in the offshore window, the last six months before the flight home.
Foreign pension lump sums. Lump-sum withdrawals from foreign pension schemes are treated very differently by the US than by the home country. A lump sum taken while still non-US-resident sits in a different US tax posture than one taken after re-entry. Timing, the elements of the payment (contribution-basis vs growth), and the home-country tax treatment all interact. Readers considering a lump-sum election should raise the US timing question with a qualified tax adviser before the election is made.
Foreign mutual funds, unit trusts and ETFs. Pooled foreign-fund holdings typically fall under the Passive Foreign Investment Company (PFIC) regime once the holder becomes a US tax resident, a distinctive tax and reporting treatment that US-domiciled funds avoid. Selling while non-US-resident and rebuilding through US-domiciled funds after return removes the PFIC overlay. The decision is the reader's, but the mechanics are materially easier pre-arrival than post.
The foreign primary residence. The §121 exclusion, which excludes a portion of capital gain on the sale of a primary residence, has its own calendar: generally ownership and use as a primary residence for at least two of the five years preceding sale. Selling the foreign home at the wrong point can miss the window. A sale before re-entry also simplifies currency and reporting. Readers who plan to keep the property as a rental enter a different regime, foreign rental income, depreciation, foreign tax credits, covered in Article 28.
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The calendar of the tax year of return does more work than most readers expect.
US tax residency start date. For US citizens, residency never stops. For green card holders who stayed abroad, typically it never stopped either. For dual-status returnees, the start date of the resident period matters and interacts with the substantial presence test. The practical effect: any income event in the year of return lands on one side of the start date or the other, and the two sides are taxed differently.
The PFIC switch. Once US residency is re-established, foreign pooled funds in a foreign brokerage begin to accrue USPFIC consequences. For a reader who didn't liquidate pre-arrival, the year of return is the last clean year to address the holding. PFIC reporting sits on Form 8621 and the choice of regime (mark-to-market, QEF, default §1291) changes the tax outcome materially.
Currency conversions. Foreign-currency cash balances held at the point of return can carry unrealized gain or loss against US dollar basis. Large conversions around the return window are US tax events, taxed as ordinary currency gain or loss. Often overlooked, because it doesn't feel like a tax event.
State residency start date. State and federal residency don't restart on the same day. If a home, driver's license or voter registration has sat in a particular state throughout the overseas period, state residency may already treat the reader as a resident by the time the flight lands. Article 18 of this series covers this in depth.
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The decisions that land in the first year back are lower-leverage than the pre-arrival ones, but still material.
US retirement accounts left behind. Many returnees have a 401(k) or IRA with a former US employer's plan that has been dormant since they left. Re-establishing US residency usually reopens rollover, consolidation and in-service options that had been impractical from abroad. The retirement-account architecture for returnees is close in shape to the one for new arrivals, covered in Article 11.
FBAR and Form 8938 for the year of return. A US person with aggregate foreign financial accounts above the $10,000 threshold at any point in the year must file an FBAR for that year, including the year of return, until the foreign accounts are closed. Form 8938 has its own, higher thresholds that vary by filing status and residence. Covered in Article 15.
Health care coverage. A gap often exists between the last day of employer-provided coverage overseas and the first day of US coverage. Medicare Part B has its own enrollment windows for returning retirees. Not a tax question, but one of the most consistent practical items in the first month back.
Source: Skybound 2026
For an American planning a return, a shortlist of questions worth raising with a qualified cross-border tax adviser and a financial planner includes:
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 financial complexity of returning tothe US is usually invisible until the first US tax return after re-entry. Bythen, most of the planning windows are already closed.
A short conversation with Tom can give youa clearer picture of where you stand and what is worth acting on first.

What looks like a 'come home' decision is in fact a structural cleanup of a decade or more of foreign holdings that theUS system now treats on its own terms.
Tom Pewtress works with US citizens returning to the US after years abroad to coordinate the pre-return cleanup andpost-return positioning.

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In a private introductory session, Tom canhelp you: