US citizen in Switzerland — VIAC and Swissquote

Facts

• US citizen, living in Switzerland.
• US filings: I'm up to date.
• Income: salary or wages, dividends or interest.
• Non-US accounts at their peak: $50,000 – $200,000.
• Non-US funds or ETFs: yes, 4 to 10 — I received distributions this year.
• Foreign pension: both.
• Filing: myself, with software.

What they hold

• Fund-based Pillar 3a (VIAC)
• Swissquote account with UCITS ETFs
• Pillar 2 occupational pension

Potential issues

• FBAR (FinCEN Form 114)Likely

  An FBAR is required when the aggregate value of your non-US financial accounts exceeded $10,000 at any point during the calendar year. It is filed with FinCEN, separately from your tax return.

• FATCA (Form 8938)Possible

  Form 8938 reports specified foreign financial assets and is filed WITH your tax return. Its thresholds are much higher than the FBAR's, and higher again if you live abroad.

• Foreign investments / PFIC (Form 8621)Likely

  Almost every fund organised outside the US — a UCITS ETF, a local mutual fund, many insurance-wrapped investments — is a passive foreign investment company for a US owner, and generally needs its own Form 8621 each year.

• Foreign pensionsPossible

  A non-US pension is generally a specified foreign financial asset for Form 8938, is often a reportable account for the FBAR, can be a foreign trust for Form 3520 unless an exemption applies, and its contributions and growth may be taxable in the US each year unless a treaty article defers them.

• Foreign companies, branches and trustsNot currently indicated

  Nothing in your answers indicates a foreign company, branch, trust or large foreign gift.

Likely forms

• US federal tax return (Form 1040)Likely

  Your worldwide gross income is above the $15,750 2025 filing threshold for single (under 65).

• FBAR (FinCEN Form 114)Likely

  Your combined non-US account peak ($50,000 – $200,000) is above the $10,000 aggregate threshold.

• PFIC reporting (Form 8621)Likely

  You hold funds or ETFs organised outside the US. PFIC status turns on where the fund is organised, not on what it holds — an Ireland-domiciled ETF tracking the S&P 500 is still a PFIC.

• FATCA Form 8938Possible

  Living abroad and filing as one person, your Form 8938 thresholds are $200,000 at year end or $300,000 at any time during the year.

• Foreign pension reportingPossible

  An occupational plan is usually a specified foreign financial asset for Form 8938, and a reportable account for the FBAR when it carries a balance in your name.

• Foreign Earned Income Exclusion (Form 2555)Possible

  You have foreign earned income and live abroad, so the exclusion is likely available to you.

• Foreign Tax Credit (Form 1116)Possible

  You paid income tax to another country, so the credit is likely the mechanism that stops the same income being taxed twice.

Likely · Possible · Needs review — likelihoods on the stated facts, never determinations.

What depends on more information

• ○Your specified foreign financial asset total on the last day of the year, and its highest point during the year, against $200,000 / $300,000.
• ○The plan's legal form under local law, whether the treaty defers taxation of it, whether you direct the investments inside it, and what those investments are.

Atamatax workflow

1. 01Gather the prior US returns you have and the local tax records for each year in scope.
2. 02Build the account list with each account's highest balance during the year — this feeds both the FBAR and Form 8938 and is the item most people underestimate.
3. 03Export brokerage statements for every year each fund was held and list each fund's ISIN; establish which holdings are PFICs before any return is prepared.
4. 04Collect the pension plan statements and rules, and establish the plan's legal form and whether the treaty defers it — this decides which forms the pension appears on.
5. 05Decide between the Foreign Earned Income Exclusion and the Foreign Tax Credit before preparing the earliest year — the choice is hard to reverse and applies year on year.
6. 06Prepare the return with its information forms, then file the FBAR separately with FinCEN — they go to different agencies with different deadlines.

Needs a professional's judgement: Foreign pension treatment: the treaty article and the plan's legal form decide which forms apply and whether growth is taxed now. FEIE versus Foreign Tax Credit: the election is hard to reverse and depends on figures this assessment did not ask for.