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Belgium, Canada, Kingdom of Saudi Arabia, New Zealand, Norway, The Netherlands

Kirsten Simmons avatar
Written by Kirsten Simmons
Updated over a week ago

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Table of contents:

Belgium

Belgian "Epargne-Pension" reporting

Belgian Epargne-Pension (Pension Saving Plan) is an IRS-qualified plan. Growth in this plan is not reportable and not taxable to the U.S. person participating in the plan until distributions from the plan are made.

Article 17(6) of the U.S. - Belgium tax treaty:

Income earned by a pension fund that is a resident of a Contracting State may be taxed as income of an individual who is a resident of the other Contracting State only when, and, subject to the provisions of paragraph 1 of this Article, to the extent that, it is paid to, or for the benefit of, that individual from the pension fund (and not transferred to another pension fund that is a resident of the first-mentioned Contracting State).

Article 1(5) of the U.S. - Belgium tax treaty: Exemption from Saving Clause:

The provisions of paragraph 4 shall not affect: ... paragraphs 1 b), 2, 5, 6, and 9 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support), ...


Canada

Canadian RRSP and TFSA accounts reporting

You are required to report RRSP and TFSA accounts on your U.S. tax return by filing FBAR (FinCEN 114) and FATCA (Form 8938). Please provide the details for your RRSP and TFSA accounts in the Non-US Financial Accounts section of the Tax Questionnaire. To do this, click the Configure Life & Income button and click Yes next to the statement I have financial accounts outside the U.S.

  • RRSP: According to the U.S.-Canada tax treaty, income deferral is only allowed for Canadian Registered Retirement plans (RRSPs). Earnings in RRSP accounts do not need to be reported to the U.S. tax authorities.

  • TFSA: TFSA is a tax-free savings account in Canada, it is not tax-free in the U.S. Earnings in TFSA accounts must be reported on the U.S. tax return.

Note: this is similar to the distinction between U.K. SIPPs and ISAs. A SIPP is an IRS-qualified retirement account with deferral allowed, whereas an ISA is an individual savings account with tax deferral in the U.K. but not in the U.S.

To report TFSA income earned in the calendar year:

  1. Navigate to Income > Passive Income and select Yes under the statement I earn interest.

  2. Click on the Interest tab at the top and click Yes under the question Did you receive non-U.S. interest income?

  3. Fill in the table.


Kingdom of Saudi Arabia (KSA)

Saudi Arabian business and investments

Opening a local business in Saudi Arabia as a U.S. citizen

Before establishing any business structure in Saudi Arabia, you must obtain an investment license from the Saudi Arabia General Investment Authority (SAGIA) under the Foreign Investment Regulations. In addition, you may need to get pre-approval from the appropriate Ministry before receiving your SAGIA license.

You will need to decide on your business structure. Saudi Arabia generally allows foreign investors to operate through five business forms: Commercial Agencies, Limited Liability Companies (LLC), Joint Stock Companies, Foreign Office branches, and Technical and Scientific Offices (Representative Offices). However, expats' most common business structures are limited liability companies and foreign office branches.


Types of local business structures in Saudi Arabia and the U.S. filing requirement

  • Limited Liability Companies (LLC) or Saudi Limited Liability Company

    The Saudi LLC is a private entity ranging from two to fifty members who are liable for the company's debts to the extent of their contributed capital. The amount of donated money must be at least SAR 500,000. Depending on the industry of the LLC, expats (or foreign investors) can wholly own this type of company without the requirement of the directors being Saudi Arabian nationals. You must report your Limited Liability Company to the IRS via Form 5471.

  • Foreign Office Branch

    Expat Companies can set up a branch office in KSA, which may carry out trading activities. The parent company would assume 100% of the branch office's debts. The branch office is subject to Foreign Investment Law and the regulator authority Ministry of Commerce and Industry (MOCI). You must report your Foreign Office Branch to the IRS via Form 5471.

  • The Stock Market

    The stock market in KSA is called Tadawul. Although it is uncommon for expats in Saudi Arabia to open a trading account, expats working there are the only category of foreign investors allowed to invest in the Saudi stock market. You will need to report your capital gains and dividend income in the Tax Questionnaire within the Passive Income section.


Saudi Arabian Social Security

The Saudi Social Security system applies to the private sector and some public workers. Individuals who do not qualify for mandatory coverage in KSA have a voluntary option for range. The Saudi Social Security system is funded with a pension that taxes 9% of the insured person's earnings (gross) in addition to the employer's contribution (9% of payroll). The self-employed pay 18%.

Saudi Arabia does not have a Totalization Agreement with the U.S. Therefore, self-employed expats must contribute to U.S. Social Security regardless of whether they contribute to KSA.


Saudi Arabian income reporting

Wage Protection System (WPS)

In 2016, Saudi Arabia's Minister of Labor announced that all companies with at least ten employees must process payments and report electronically via the Wage Protection System.


WPS template


Salary slip

Wage statement: If you are employed in Saudi Arabia, you will likely receive payment via direct deposit and a salary slip provided by your employer via the Wage Protection System.


Beneficiary basic salary

Gross salary: To report the total amount of the annual gross salary:

  1. Open your Tax Questionnaire and click the Configure Life & Income button on the left side.

  2. Click Yes next to I receive payments from an employer.

  3. Click Next Step and Submit.

  4. Navigate to Income > Wages and click Yes to the question Did you receive payments during the tax year from a non-U.S. Employer?

  5. Enter the gross salary amount to the question Gross wages/salary earned with this employer during the tax year? Use the income calculator to convert to a calendar year.


Housing allowance

A housing allowance is an allowance provided by your employer on top of your direct salary. Please include this in the Tax Questionnaire under Income > Wages, click Yes under the question Did your employer provide an allowance on top of direct salary (car, education, home leave, etc.)? and fill in the table.


Transportation allowance

Transportation allowance is an employer's allowance on top of your direct salary. Please include this in the Tax Questionnaire under Income > Wages, click Yes under the question Did your employer provide an allowance on top of direct salary (car, education, home leave, etc.)? and fill in the table.


Overtime

Overtime pay received should be added to your gross wage amount in the Income > Wages section.


Bonus

Bonus pay should be added to your gross wage in the Income > Wages section.


Saudi Arabian financial accounts reporting

Which types of KSA financial accounts must the U.S. individual report on FBAR / FATCA?

  • Individual bank accounts include savings accounts, checking accounts, and time deposits.

  • Brokerage accounts, commodity futures or options accounts.

  • Insurance policies and annuity contracts with a cash value (i.e., such as a whole life insurance policy).

  • Business accounts where a U.S. person has a greater than 50 percent interest in the entity.


Which types of KSA financial assets are not required to be reported on FBAR / FATCA?

  • Social Insurance.

  • Real Estate Holding.

  • Precious metals held directly.

  • Collectibles.

  • Financial account held at a U.S. branch of a foreign financial institution.


New Zealand

New Zealand businesses and investments

Opening a local business in New Zealand as a U.S. citizen

Before opening a local business in New Zealand, you must obtain the appropriate visa to obtain the right to live and work in New Zealand. Also, you must decide on your business structure, which determines the liability of your business debts and tax obligations.

Moreover, you will need to contact the agencies in charge of registering and issuing licenses to New Zealand businesses. The agencies include Inland Revenue, The Companies Office, and the Regional Council. For tax purposes, all companies must register with Inland Revenue. The Companies Office is the New Zealand government agency responsible for corporate body registers. Before opening your business, the appropriate licenses and permits must be obtained from the Regional Council.


Types of local business structures in New Zealand and the U.S. filing requirement

  • Sole Trader

    A sole trader is a business run by a single owner who possesses complete control and assumes personal responsibility for the company's liabilities. As a sole trader, you are self-employed. You must report your self-employment to the IRS via form Schedule C (included in our PREMIUM package).

  • Limited Liability Company (LLC)

    The limited liability company is the most common amongst expats, as the LLC offers better protection than the sole trader and partnership business structures. The LLC is a formal and legal entity separate from its owners or shareholders. The LLC's shareholders are only liable for losses up to the amount of their share of ownership in the company. You must report your LLC to the IRS via Form 5471.

  • Partnership

    Expats planning to go into business with one or more people may decide to register their business as a partnership. The partnership business structure can be an effective way to share business operation costs. You must report the partnership to the IRS via Form 8865.


New Zealand Stock Exchange (NZX)

There are over 200 companies listed on the New Zealand Stock Exchange (NZX). Expats may buy shares of these publicly listed companies traded on the NZX. Expats also can buy shares of private companies not listed on the NZX. Expats planning on investing will need the appropriate visas.

Investments on the NZX can be made directly through an NZX broker. When buying shares in private companies, an investor should consult a business broker or a legal/financial professional. For tax purposes, you must retrieve a statement from your broker detailing all stocks and securities purchased or sold during the year. The statement should outline the purchase price, transaction fee, and purchase/sale date (as these details are relevant to your tax return).


New Zealand bonds

New Zealand offers a range of fixed-interest bonds, which can be purchased through investment advisers, share brokers, and the NZX Debt Market (NZDX). The NZDX Market also provides a secondary market where investors can buy and sell debt securities such as corporate and government securities (i.e., Kiwi Bonds). Kiwi Bonds are only offered to New Zealand residents. Even if New Zealand citizenship is held, the investor is ineligible if they reside outside of New Zealand. Any information regarding income generated through interest or dividends should be provided to your tax preparer.


Social Security and pensions

New Zealand has a three-pillar pension system.

  • Pillar I - NZ Superannuation (NZS): It is a non-contributory state pension. NZS aims to provide social security to all residents fulfilling the residence requirements at age 65.

  • Pillar II - Occupational superannuation schemes and the KiwiSaver scheme: The KiwiSaver scheme is a voluntary, work-based scheme with the primary objective of complementing and increasing overall retirement savings. Contributions to the KiwiSaver plan are voluntary for employees and employers. In addition to paying ongoing account fees, the government contributes NZD 1000 to the KiwiSaver upfront.

  • Pillar III - Private-sector occupational schemes: They are provided through registered or unregistered superannuation schemes. The occupational schemes are offered alone or as part of a master trust.


New Zealand income reporting

Your Personal Tax Summary (PTS) indicates your income and the amount of tax withheld by your employer for the tax year from April 1 to March 31.

Gross salary or wages

To report the total amount of the annual gross salary:

  1. Open your Tax Questionnaire and click the Configure Life & Income button on the left side.

  2. Click Yes next to I receive payments from an employer.

  3. Click Next Step and Submit.

  4. Navigate to Income > Wages and click Yes to the question Did you receive payments during the tax year from a non-U.S. Employer?

  5. Enter the gross salary amount to the question Gross wages/salary earned with this employer during the tax year? Use the income calculator to convert to a calendar year.


Interest, dividends and taxable Māori authority distributions

To report interest:

  1. Navigate to Income > Passive Income and select Yes under the statement I earn interest.

  2. Click on the Interest tab at the top and click Yes under the question Did you receive non-U.S. interest income?

  3. Fill in the table.

To report dividends:

  1. Navigate to Income > Passive Income and select Yes under the statement I earn dividends.

  2. Click on the Dividends tab at the top and click Yes under the question Did you receive non-U.S. dividends?

  3. Fill in the table.


Tax on taxable income

This amount represents the total tax assessed on your taxable income. The amount of foreign income tax paid or withheld can be utilized as a Foreign Tax Credit (FTC) to offset U.S. tax liability. The amount can be found in your Personal Tax Summary (PTS):

Report tax imposed on the particular income type in the Taxes & Deductions > Taxes Paid section of the Tax Questionnaire (TQ), click Yes under the question Did you pay any tax to any non-U.S. country on any of your income this year?


The percentage of income tax allocated to Social Security equivalent in New Zealand

It is shown on your paystub as employee KiwiSaver deductions.


New Zealand financial accounts reporting

You may meet the filing requirement to disclose your foreign accounts on FBAR if you have bank accounts at Commonwealth Bank (CBA), Westpac, National Australia Bank, Australia and New Zealand Banking Group (ANZ), or at another bank in New Zealand or any other foreign country.

Which types of New Zealand financial accounts must the U.S. individual report on FBAR / FATCA?

  • Individual bank accounts include savings accounts, checking accounts, and time deposits.

  • Retirement accounts.

  • Brokerage accounts, commodity futures, or options accounts.

  • Insurance policies and annuity contracts with a cash value (i.e., such as a whole life insurance policy).

  • Business accounts where a U.S. person has a greater than 50 percent interest in the entity.


Which types of New Zealand financial assets are not required to be reported on FBAR / FATCA?

  • Social Insurance.

  • Real Estate Holding.

  • Precious metals held directly.

  • Collectibles.

  • Financial account held at a U.S. branch of a foreign financial institution.


Norway

Norwegian Aksjesparekonto - Stock savings account (ISA)

Aksjesparekonto (ASK) is a tax-deferred savings and investment account in Norway. It does not qualify for income deferral in the U.S. Income earned on those accounts must be reported on U.S. tax returns.

To report interest:

  1. Navigate to Income > Passive Income and select Yes under the statement I earn interest.

  2. Click on the Interest tab at the top and click Yes under the question Did you receive non-U.S. interest income?

  3. Fill in the table.

To report dividends:

  1. Navigate to Income > Passive Income and select Yes under the statement I earn dividends.

  2. Click on the Dividends tab at the top and click Yes under the question Did you receive non-U.S. dividends?

  3. Fill in the table.


The Netherlands

Dutch businesses and investments

Opening a local business in the Netherlands as a U.S. citizen

Before opening a local business in the Netherlands, you must have the right to live and work in the Netherlands. You will need to apply for a residence permit (MVV) and, sometimes, a work permit (TWV). What's more, you must decide on your business structure, which determines the liability of your business debts and tax obligations.


Types of local business structures in the Netherlands and the U.S. filing requirement

The Netherlands has several business structures divided into two groups: Unincorporated business structures (no legal form required) and Incorporated business structures (needed legal document):

  1. Unincorporated Business Structures (Rechtvormen zonder rechtspersoonlijkheid) include Eenmanszaak: sole trader, Vennootschap onder firma (VOF), Maatschap, and Commanditaire vennootschap (CV). These unincorporated businesses can be registered directly with the Dutch Chamber of Commerce (KvK) without a notarial contract.

    • Sole Trader (Eenmanszaak)

      As a Sole Trader, you are self-employed. You must report your self-employment to the IRS via form Schedule C (included in our PREMIUM package).

    • VOF, Maatschap, and CV

      Expats planning to go into business with one or more people may decide to register their business as a partnership. There are various types of blocks in the Netherlands, including Vennootschap Onder Firma (VOF): general partnership, Maatschap: professional partnership, and Commanditaire Vennootschap (CV): limited partnership. You must report the partnerships mentioned above to the IRS via Form 8865.

  2. Incorporated business structures (Rechtvormen Met Rechtspersoonlijkheid) include Besloten vennootschap (BV): private limited company, Naamloze vennootschap (NV): public limited company, Stichting: foundation, and Coöperatie: cooperative or collective. These incorporated businesses can be registered directly with the Dutch Chamber of Commerce (KvK) and require a notarial contract. You will be required to report the corporations mentioned above to the IRS via Form 5471.


Social Security and pensions

The Dutch pension system comprises three pillars:

  • Pillar I - The state or AOW (Algemene Ouderdomswet) pension (Basispensioen): It is an insurance scheme that covers Dutch residents aged 67 or older, who live or work in the Netherlands, regardless of their income, wealth or nationality. In addition to surviving partner pension and specific health costs, your Dutch Social Security contribution is considered coverage for the state pension. AOW is funded by contributions from the working population.

  • Pillar II - Occupational pensions (Pensioenfondsen): Employer-sponsored pension plans provide additional retirement income. Many Dutch workers are enrolled in collective pension funds managed by pension funds or insurance companies that are often industry-specific. Employers' and employees' contributions will not be included in current-year taxable income (exempt by a tax treaty).

  • Pillar III - Voluntary individual pension funds or supplements: Pillar III mainly uses self-employed individuals and employees in industries with no collective pension funds. Individual pension products may include life insurance, shares, or property. There are various tax advantages and incentives for individuals to save for retirement in this way.


Dutch tax glossary

  • Loon LB/PH - The wage for taxes and national insurance contribution.

  • Ingehouden LB/PH - Wage tax and national insurance contributions withheld.

  • Verrekende arbeidskorting - Settled labor discount.

  • Loon Zvw - The wage for premium health care insurance.

  • Werknemersbijdrage Zvw - Employees' contribution to health care insurance.

  • Werkgeversheffing Zvw - Employers' contribution to health care insurance.

  • Verr. Levenslooopverlofkorting - Settled life-course savings.

  • W.G. bijdrage S.V. - Employers' contribution to social security.


Dutch income reporting

Totaal Inkomsten Ult Werk En Woning - Gross salary

To report the total amount of the annual gross salary:

  1. Open your Tax Questionnaire and click the Configure Life & Income button on the left side.

  2. Click Yes next to I receive payments from an employer.

  3. Click Next Step and Submit.

  4. Navigate to Income > Wages and click Yes to the question Did you receive payments during the tax year from a non-U.S. Employer?

  5. Enter the gross salary amount to the question Gross wages/salary earned with this employer during the tax year? Use the income calculator to convert to a calendar year.


Premie Volksverzekeringen - Social Security contributions

All Dutch residents are required to contribute to the country's Social Security scheme. A totalization agreement is in place between the Netherlands and the United States, providing guidance on the country to which Social Security taxes must be submitted. Generally, if a taxpayer is sent to the Netherlands to work by a U.S. company for under five years, they pay taxes into the United States Social Security system. If a taxpayer is hired within the Netherlands, recruited by a Dutch company, or plans to work in the Netherlands for longer than five years, they pay into the Dutch system.

Due to the Totalization Agreement between the U.S. and the Netherlands, you are not required to report the amount you paid to the local Social Security system in the Tax Questionnaire.


Totaal Inkomstenbelasting - Total income tax

Report tax imposed on the particular income type in the Taxes And Deductions > Taxes Paid section of the Tax Questionnaire (TQ), click Yes under the question Did you pay any tax to any non-U.S. country on any of your income this year?


Ingehouden Loonheffing - Income tax withheld

The amount of foreign income tax paid or withheld can be utilized as a Foreign Tax Credit (FTC) to offset U.S. tax liability. Report tax imposed on the particular income type in the Taxes And Deductions > Taxes Paid section of the TQ.


Dutch financial accounts reporting

Which types of Dutch financial accounts must the U.S. individual report on FBAR / FATCA?

  • Individual bank accounts include savings accounts, checking accounts, and time deposits.

  • Retirement accounts - balance on Pillar 2 and Pillar 3 accounts.

  • Brokerage accounts, commodity futures or options accounts.

  • Insurance policies and annuity contracts with a cash value (i.e., such as a whole life insurance policy).

  • Business accounts where a U.S. person has a greater than 50 percent interest in the entity.


Which types of Dutch financial assets are not required to be reported on FBAR / FATCA?

  • Social Insurance.

  • Real Estate Holding.

  • Precious metals held directly.

  • Collectibles.

  • Financial account held at a U.S. branch of a foreign financial institution.

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