Pension · Switzerland
Swiss vested-benefits (Freizügigkeit) accounts & U.S. tax
When you leave a job or Switzerland, your 2nd-pillar can move to a vested-benefits account — here's the U.S. reporting and the PFIC angle.
By Danilson Ramos · Founder, Atamatax
Published July 2026 · Updated September 2026
A vested-benefits account (Freizügigkeit / libre passage) holds your 2nd-pillar assets when you leave an employer or Switzerland without immediately transferring into a new pension. For a U.S. person it raises the same two questions: reporting, and whether it holds PFICs.
Reporting
- Generally a reportable foreign account — on the FBAR if combined non-U.S. accounts exceed $10,000 at any point.
- And on Form 8938 if you cross the higher abroad thresholds.
The PFIC angle
Vested-benefits accounts come in two flavours — an interest-bearing (bank) account, or an invested one holding funds. An invested vested-benefits account holds non-U.S. funds, so those are generally PFICs needing Form 8621. An interest-only one has no PFIC.
Check your reporting and your funds
See whether you cross the FBAR and Form 8938 thresholds, then check any funds for PFICs. This is general information, not individualised tax advice.
Authorities cited
- FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
- 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
- IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
- IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.