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Pillar 3a · Switzerland

VIAC, finpension & Frankly for U.S. citizens

Which Swiss Pillar 3a providers accept U.S. persons, and why the funds inside a 3a are PFICs that need Form 8621.

By Danilson Ramos · Founder, Atamatax

Updated July 2026

Tax review partner: onboarding in progress. This article has not yet been independently reviewed by a credentialed professional — every figure cites its IRS source so you can verify it directly.

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The three big digital Pillar 3a providers — VIAC, finpension, and Frankly — are excellent for Swiss savers. For a U.S. person the questions are: can you even open one, and what does it do to your U.S. taxes?

Can a U.S. person use each provider?

ProviderU.S. personsNotes
finpensionRestrictedStates it cannot offer its investment solution to U.S. persons; registration asks you to confirm you are not a U.S. person.
VIACReported possibleSome U.S. persons report being able to open and invest a 3a — with the reporting burden on them. Confirm current terms.
FranklyConfirm directlyA fund-based 3a; confirm its current U.S.-person policy with Frankly before relying on it.
This is commentary except where noted (finpension's own FAQ), and providers change their policies — confirm directly before relying on any of it.

The part that doesn't change: the funds are PFICs

Whichever provider you use, an invested 3a holds Swiss- or Irish-domiciled funds. For a U.S. person those are PFICs, each generally needing its own Form 8621 under the default §1291 rules. The 3a wrapper doesn't remove that.

A cash / interest-only 3a holds no funds — no PFIC (still reportable). It's the invested 3a that creates Form 8621 work.

What to do

  • Identify each fund inside your 3a and its domicile.
  • Expect Form 8621 per non-U.S. fund held.
  • Report the 3a on FBAR / Form 8938.
  • Decide whether a fund-based 3a is worth the U.S. filing cost for your situation.

Which of your 3a funds are PFICs?

Pick your provider in the free Swiss PFIC checker and see whether your 3a means Form 8621. Atamatax is tax-preparation software, not a CPA firm, and this is not individualised tax advice.

Provider policies change — confirm with VIAC, finpension, or Frankly directly. Atamatax provides preparation software and educational estimates, not individualised tax, legal, or investment advice.

Authorities cited

  • IRC §1297IRC §1297 — Definition of a passive foreign investment company
  • IRS Form 8621About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
  • IRC §1291IRC §1291 — Interest on tax deferral (excess-distribution regime)
  • IRS Form 8938About Form 8938 — Statement of Specified Foreign Financial Assets
  • FinCEN Form 114 (FBAR)Report of Foreign Bank and Financial Accounts (FBAR)

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.

Frequently asked questions

Can I open a finpension 3a as a U.S. citizen?
finpension states it cannot offer its investment solution to U.S. persons — at registration you're asked to confirm you are not a U.S. person. Confirm current terms with finpension.
Can I invest a VIAC 3a as a U.S. person?
Some U.S. persons report being able to open and invest a VIAC 3a, with the reporting burden on them. Practices change, so confirm directly with VIAC — and remember the underlying funds are still PFICs.
Are the funds in my 3a PFICs?
Non-U.S.-domiciled funds inside an invested 3a are PFICs for a U.S. person, each needing Form 8621. A cash 3a has none. It turns on the fund's domicile, so check what's actually inside.

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