Taxes in retirement for Americans

hi there,
I'm planing to retire in Spain (around Barcelona) but the main concern are taxes. I did online research but found incomplete or confusing information about taxation in retirement. Here is my info:
I'm US and also Slovakia-EU citizen and my wife only US citizen living now in US. We have US retirement accounts 401k, IRA, Roth IRA and also regular investment account with stocks. Later we will receive government social security payments. My questions would be:

1. I'm planning to use maybe $50-70k a year to live and travel in Spain. I would draw that money from US investment account first and then 401k, IRA and later social security payments. On all of these accounts I have to pay taxes to US (accept Roth IRA) but does Spain will tax me on any of above retirement accouts? Spain taxes on 50-60k would be high 45%, in US I would only pay maybe 15% after deductions. OR are foreign retirement accounts exempt from tax? Paying 45% versus 15% looks too high.

2. I will sell my house and keep the proceeds in checking or investment account in US, tax free in US. Any tax consequences from that money in Spain after the sale? Assets reporting? I would sell house before I move to Spain and just invest it in stocks.

3. As EU citizen I don't need visa but my wife needs probably non-lucrative visa. Since I don't live or work in EU, I do not have now any health insurance in EU, I have just EU passport. What health insurance am I eligibe in Spain OR do I have to buy and at what cost, approximately for person in 50y+ old?

4. We plan to live permanently in Spain. What residency is the best for tax purposes in above scenario, me as EU+US citizen and wife as US citizen, both not working? We also have 1 child 9y old but that probably does not matter?

Thank you for all your info!
Eric

I'm interested in this topic as well.  From what i understand, Spain taxes worldwide income.  Are the distributions from US social security, 401k considered income.  The US taxes them after all.  Will Spain tax these?

Regarding Spanish wealth tax, will that cover all of ones retirement savings from 401k, IRA?

How does the double taxation treaty between the US and Spain eliminate or reduce the tax burden for retirees?

And what about the inheritance tax?  Anyone has any experience with this?

@Erichsisol - When considering a region, if you are concerned with taxes, consider the implication of wealth and inheritance taxes.  These, apparently, are set per autonomous region.  Below are 2 articles that you may find useful.

Inheritance Tax - See section on "How is the regulation of the Inheritance Tax in the different regions of Spain?"

[url=https://www.blevinsfranks.com/news/articles/spain-wealth-tax-rates-and-allowances[/url]- See section on "Wealth tax rates and allowances in Spain"

I still cannot find any blogs on how the double taxation treaty is applied to distributions to social security, 401k, and IRA.  I suspect though that Spain will tax them as income but possibly allow the deduction tax paid to the US.  In other words, if your tax bracket in Spain is 30%, then you will pay an aggregate of 30% in the end.  I cannot find any information that references any allowance.  Double taxation treaty does not imply that the other state cannot tax your income.  Take the case of US expats.  They still have to pay the US any income above $110 USD (minus some deductions).

I suspect 401k and IRA will be considered investment accounts.  I've contacted a 2nd lawyer today.  The first one didn't reply.

Thank you dennislg! I'm still very curious about all US expats from US living in Spain who retired. If Social security + 401k + IRA are taxed in Spain that would be a big burden.
1/ Let's say me and my wife will be taking total 50k USD a year from above retirement accounts to live in Spain and support son's college. In US we have automatic tax deduction of 24k and the leftover income 26k would be taxed very little, perhaps 15% since for US this is kind of low income. On the other hand if Spain will tax me on 50k retirement income then I might pay about 40% in taxes?? I'm wondering if US retirees really pay that much in Spain from retirement accounts? That would deter me from moving to Spain.

2/ Another topic would be Roth IRA account, which is tax free in US in retirement. How about Spain?

3/ Lastly regular investment accounts which have capital gains and dividends. Would that be considered 'earned' income and taxed in Spain OR otherwise?
In US if I live in low tax bracket under $80k USD per couple then my long term capital gains tax is 0% and dividends same as income (my case 15%). If taxed in Spain, they have no idea what is my cost basis so I can report no gains? US investment accounts report cost basis only to IRS but not overseas I guess?

I fully understand if I earn any income or work in Spain which would be taxed by Spain tax rates. But this is passive retirement income and not earned, like savings.

Any info will be much appreciated!
Erich

I am also wondering about this topic. From what I read, I was under the impression we do not have to file anything or pay taxes in Spain, but I am now beginning to wonder if that is correct. Does anyone know of a tax lawyer or accountant in the Barcelona area who is experienced in dealing with Ex-pat Americans? There are a lot of British people here, and the rules for them are different (at least for now - once Brexit goes through it may change).

Lots of questions. I recommend consulting with one of the online companies that do international taxes. From my own situation, I know the following:
1) Both Spain and the US tax all international earnings. Tax treaties are set up so that one is not double taxed. The county that you live in is your tax home, for me that is Spain,  and that affects how you do your returns.
2) Your taxes depend upon where your earnings come from.  My wife is Spanish, but has permanent residency in the US (green card). Both of us are required to file in both countries. All of her income is from Spanish sources (work).  She files and pays taxes in Spain and files in the US with a foreign income exclusion (and pays no US taxes).
3) Because Spanish tax laws do not give much of a break to married couples  and because my wife and I have similar incomes, our Spanish accountant has us file separately in Spain, so that we both fall in lower income categories.
4) At present, my income is all derived from a private retirement, a benefit of my US employer. According to the Spanish tax treaty BOE, my tax home being Spain, all taxes from my private pension are paid to Spain, and I am taxed here on my yearly income converted to Euros (as established by Spanish hacienda). My income of about $34,000/yr is taxed at around 20%, I think. I declare these taxes on my 1040 as well as other small amounts of income and the US refunds most or all of my withheld taxes.
5) I have held off on collecting Social Security  but will begin collecting next year. According to the Spanish BOE, my taxes from income from social security will be paid to the US. I assume that I will move to a higher tax bracket in both countries next year.
6) I do not know which if any deductions are applied to my Spanish taxes. My wife and I have a 22 year old son.
6) I recommend using an international/online firm to do the US taxes. It is a lot of work to figure it out yourself. Spanish accountants are very reasonable. I pay around 100 Euros for my simple return, and can do the return online and submit it.

When you said "private retirement", are you referring to 401k and IRA? 

When you said "income" from this private retirement, are you referring to the distribution or withdrawals from the 401k and IRA?  Is it correct to assume that dividends and interest income generated within the 401k are not taxable until they are withdrawn from the retirement account?

Spain has a wealth tax.  Are 401k and IRA included in the calculation of the wealth tax?

I have a private pension from a company in the US.  Don't know the answer to the other questions, but I assume that interest and income are not taxable until retired from 401K and IRAs as per US law. Here is the Spanish BOE and explanation, but it is in Spanish. There is also a simplified explanation on the web somewhere. I couldn´t find my copy.

https://www.boe.es/buscar/doc.php?id=BOE-A-1990-30940

I have a photocopy of the original, BOE núm. 306, sábado, 22 diciembre 1990, pg. 38256. The simplified interpretation states plainly that taxes on state pension (soc. sec.) are paid to the state paying the pension. Taxes on private pensions go to Spain. I would assume IRAs and 401ks are private. For my private pension I pay all taxes to Spain.

Carl

I attended a webinar on US/Spain Taxes for Expats today. 

1) 401k and IRA assets are included in the calculation of the wealth tax.  Each region has their own allowance which may or may not affect your tax burden.  Per my previous research, Madrid has the best with a 99% allowance.

2)  Double tax treaty is not straight forward.  Someone has to invoke Article 10 and that has to be accepted.  But you'll have to pay the tax you owe each country and file for a refund from one of them after.

3) They explained the difference between how the US and Spain taxes.  The US taxes based on citizenship while Spain is based on residency.  So, for US citizens, you will have to pay the US no matter where you are.  For Spain, you only pay Spanish taxes if you reside in Spain.

I can't remember if social security benefits will be taxed by Spain.  They recorded the webinar.  If they make those recordings public, I'll post the link.

I'm super confused.  I've read, and read, and read.  I see a lot of tax information about "expats" moving to/living in Spain, but not a lot of tax info about expats who are drawing a government pension check.

I'm retired.  I receive a government defined benefit pension from a municipality (city firefighter). Pretty good size monthly benefit.  We are interested in relocating to Spain.  Will we have to pay income tax to US and Spain????  I don't understand treaty dealing with double taxation.

Will I be responsible for paying the US taxes only?  Do I pay the US, then calculate the Spanish income taxes, and pay the difference to Spain (on top of my US taxes)?  Or, will my government pension be exempt from Spanish income taxes as long as I file and pay taxes to the US? 

Help!  Thank you.

I'm facing a similar situation and have concluded that there is a tax liability in Spain for US citizens classified as “tax residents”, and It is complicated..

Since the US tax code itself is quite complicated, and not withstanding any tax treaties between US and Spain, I have opted not to pursue residency in Spain.

What's clear is that you will have to file tax returns to both US and Spain.  Since residents of Spain are taxed on worldwide income which include pension distributions, Spain may want you to pay the taxes to them.  If that happens, you can declare the tax you paid Spain as a deduction to your US tax return.  This is more likely because normally you pay your country of residence. But best to consult with a tax consultant.

Can the current expats share their experience on this?

I read with interest your note that investments held in IRA's and 410k's count as assets for the wealth tax. This in-depth article states otherwise:

“In order for us to consider a foreign financial product as a pension plan and not have to declare it in 720, the following requirements must be met:
1. That the contributions are unavailable until a contingency covered by the plan or pension product occurs.
• The contingencies covered can only be: retirement, survival, widowhood, orphanhood or disability.
• That once the contingency has occurred it has not been redeemed (once it is redeemed, the income or capital redeemed must be declared)

Examples:
401 (K) plans in the United States are pension plans: they do NOT have to be declared. Nor, the “deductible IRA” (Individual Retirement Account).

The consensus seems to be that Traditional IRA and 401ks qualify under these assumptions (although technically IRAs and 401ks can be redeemed with a tax penalty, this gets glossed over).”

https://htj.tax/2020/10/tax-residents-i … om-the-us/

Thank you very much for good info!

Well, that is a goodly budget for living in Spain. Even with taxes you should have a very comfortable retirement. :-)

I am not an expert on Spanish tax, and this sounds complicated enough that you probably should see a tax specialist before becoming a Spanish tax resident (by spending more than 183 days here). As an EU national, it might be worth considering giving up your US citizenship too, as that obligates you to pay US taxes, even if you've retired to sunny Spain and never return.

I do know that there is a double taxation treaty between the two, so that's a plus. It's a generalization, but I'd say that, in most cases, US taxes are lower than the Spanish taxes. So that means, effectively, that you'd pay USA first, then pay the difference (because of the double taxation agreement) to Spain. That means that giving up the US citizenship wouldn't matter - but I'd be surprised if that really turns out to be the case. (At the very least, you'd save the faff of two tax returns and expensive accounting advice.)

Some folks get confused between "legal residence" and "tax residence". The former is going through the immigration formalities and getting your residence permit (or EU citizen registration certificate in your case). Sometimes this does result in tax residence too, but in most countries (including Spain, I believe) it doesn't, and so is based on your physical presence (over 183 days per year), or perhaps your "center of economic interests" (where most of your wealth/economic activity is). As a legal resident you can come and go to your Spanish home and stay as little/long as you like. But to avoid the tax residence you'll need to count your days.

Avoiding the 183 threshold might be a hassle if you keep flying back to high-cost USA, but you could easily have another residence in a low-tax EU country (Ireland, Bulgaria, Cyprus). It's fine to have multiple legal residences (I have mine in Bulgaria, Cyprus, Spain).

The easy ones:

(2) Your house sale occurs before you become a Spanish tax resident. So taxes on the sale itself are a US-only issue. But I believe there is a "wealth tax" in Spain, based on your assets (in Spain if not yet tax resident, worldwide if a tax resident). It's not very high, but if it's a $5m waterfront pad in Sausalito, then it all adds up. If the funds generate interest then that's part of your taxable income too.

(3) Indeed, lucky you, you don't need a visa! :-) EU passport holders can relocate to any EU country with minimum formalities. The registration process requires proof of funds (ideally Spanish bank account with a few thousand euros), proof of Spanish address (a property you've purchased, or a long term rental contract), and proof of health insurance. Health insurance gets expensive with increasing age, prior medical issues. But ballpark 1k-2k euros per year, I'd guess. Once resident you could register and make social security contributions to qualify for state healthcare.

Once you've completed the immigration formalities, as a legal resident you can do "family reunification" to get your wife's (and your child's) residence permit (no visa required).

(4) There is no residence "type" in your case. You're entitled to residence as an EU citizen. Then your wife (child), ditto, as wife (child) of EU citizen / Spanish resident. So your choice is therefore between becoming a Spanish tax resident (more than 183 days) or not (less than 183 days). And, if the latter, where else are you spending your time? And do you want to keep paying taxes to Uncle Sam when you don't avail yourself of his services.

By way of contrast, I bought our little pad in Elche for 27k on Ebay, and it is a delight (after a gut renovation, of course). Our monthly expenses for this are around 150 euros a month. My partner's health insurance is 300 euros per year. We're pretty low-key (my idea of a trip is a hike along the Rio Vinalopo trail for a couple of hours, with a coffee and a napolitana at Mayte's on the way back), so we're quite comfortable on 1k a month. :-)

To avoid confusion, the justification for residence I previously listed (3 proofs: funds, home, health insurance) is for the "economically inactive" (retired/unemployed/lazy). EU citizens can justify their residence based on employment, self-employment, or studying too, but it's a bit of a faff IMHO. Once you have your residence permit you are not obligated  to stay economically inactive (unlike a no lucrativa visa, for example), so you can chill on the beach... or be self-employed... or start a Spanish business... or even take a job.

Also... with a child... you're just a teeny bit less mobile as they'll soon be fluent in Spanish and enjoying their local Spanish school. So it will be harder for you to avoid becoming a tax resident (there's a wife rule too, I think, so it makes it almost impossible even if you, personally, want to keep dodging). So it's probably worth figuring out the real impact before you make the decision to relocate.

For extra confusion, there are some taxes to pay even if you're not a Spanish tax resident. :-) e.g. property taxes on your Spanish properties, tax on rental income from your Spanish properties, tax on the imputed income from your Spanish home, tax on your Spanish wealth. I personally find the Bulgarian 10% flat tax on all forms of (actual) income much less stressful. :-)

thanks for simplifying and analyzing ways to retire in Spain, I just don't understand why Portugal and Spain just want to penalize people that what to retire in their countries. Are foreign retirees considered a burden to their social services and infra structure without bringing any benefit to their government?
   May i suggest for them to look the positive in welcoming some little benefits in this scenario. I'm a us retiree and considering moving to other country due to cost of living in California is costly. MY income from 401k and social security adds up to $3500/mths and barely pay any income taxes here in US. So spending and bringing in $42k to the economy without them exporting any product as trade is a plus to their trade deficit.
   So what is their motive in encouraging a lot of retired expat to migrate to their country? Retiree's worked 30 plus years of hard labor to be able to earned social security income.
Are  there any countries  that  will TAX Exempt social security pension which was not earned in their country?  Thank you all for posted information, it will really help to really make anyone thinking of moving overseas to thread carefully.

You're right! Not only that you will be taxed in Spain, but also in the USA

From my research your government pension and social security are exempt from being taxed by Spain. Still reviewing on other sources of income to make a full determination. I am city employee so major consideration

According to provision 21.2 of the DTA Spain-US in regards to Public Pensions states that Pensions paid by a Contracting State or one of its political subdivisions or local bodies, either directly or out of constituted funds, to an individual in respect of services rendered to that State or to that subdivision or body, may be taxed only in that State.

(b) However, such pensions may be taxed in the other Contracting State only if the individual is a resident and a national of that State.

gwynj wrote:

...tax on your Spanish wealth....


OK. That's a new one for me. So if I keep €100 000 in a Spanish bank (forget the personal exemption for now), and I am not a Spanish tax resident, I have to pay a wealth tax on that money? Just to clarify, I am not talking about the interest from it, but the principal.

Bosaj50 wrote:

From my research your government pension and social security are exempt from being taxed by Spain. Still reviewing on other sources of income to make a full determination. I am city employee so major consideration


I believe Spain will not tax that portion of social security benefits that is attributable to government employment, but will tax the rest of the social security benefit.  I first got onto this division when watching a presentation video from hijo.tax, then spoke with a Spanish tax lawyer, who confirmed it and mentioned that the calculation is done with a spreadsheet.

  Article 20.1(b) of the tax treaty permits the state paying the benefit to tax it, but it does not preclude the other state from taxing it (that is, the word “only” is missing).

Finally, while Spain may not tax government pension income, the income does factor into determining your Spain tax bracket, thereby increasing taxes owed for income that Spain does tax.

conradmilpitas wrote:

Are  there any countries  that  will TAX Exempt social security pension which was not earned in their country?  Thank you all for posted information, it will really help to really make anyone thinking of moving overseas to thread carefully.


France, for one.  Under the tax treaty, all US retirement income is exempt (or, more specifically, France will apply a tax credit equal to the tax you would otherwise pay).

As for the policy matter, I think it helps to think of it in terms of the cost of residing in a country with an advanced infrastructure and many other benefits.  I travel on roads, benefit from police protection, etc.  Taxation of worldwide income is the norm because where else will the money come from if it could be offshored to avoid taxation?  You'd end up with an awful lot of free riders.  It's the US policy of taxing based on citizenship even absent residency that's the exception.

Regarding the quote of the tax treaty, I don't see the sub (b) that you are listing when I read the treaty. Where are you getting your quote?

marialuisa7677
According to provision 21.2 of the DTA Spain-US in regards to Public Pensions states that Pensions paid by a Contracting State or one of its political subdivisions or local bodies, either directly or out of constituted funds, to an individual in respect of services rendered to that State or to that subdivision or body, may be taxed only in that State.

(b) However, such pensions may be taxed in the other Contracting State only if the individual is a resident and a national of that State.


I am preparing to move to Spain in July and read the treaty completely and focused closely on Article 21 as I will have a government pension and social security benefits. Here is a link to the document on the IRS website: https://www.irs.gov/pub/irs-trty/spain.pdf
What I understand it to be saying is that pensions from government (federal, state, county, city....) entities can only be taxed in the country in which they were accrued. I worked for San Diego County so the US is the only country that can tax those benefits.

And (b) says the exact opposite of what you are stating. You use the term "other Contracting State" by which I assume you are meaning Spain. That statement does not exist in the document from the IRS.

(b) in the treaty is a statement about social security benefits.

Now let me say thank you to all who have shared their experience of being taxed as a US citizen living in Spain. The real life stories are very beneficial. I will not be a tax citizen of Spain in 2022 as I will not be there for more than 183 days (thus still considered a non-resident). But I will in 2023 and hope I remember to come back and let y'all know my experience.

yajubilado wrote:

Regarding the quote of the tax treaty, I don't see the sub (b) that you are listing when I read the treaty. Where are you getting your quote?

marialuisa7677
According to provision 21.2 of the DTA Spain-US in regards to Public Pensions states that Pensions paid by a Contracting State or one of its political subdivisions or local bodies, either directly or out of constituted funds, to an individual in respect of services rendered to that State or to that subdivision or body, may be taxed only in that State.

(b) However, such pensions may be taxed in the other Contracting State only if the individual is a resident and a national of that State.


I am preparing to move to Spain in July and read the treaty completely and focused closely on Article 21 as I will have a government pension and social security benefits. Here is a link to the document on the IRS website: https://www.irs.gov/pub/irs-trty/spain.pdf
What I understand it to be saying is that pensions from government (federal, state, county, city....) entities can only be taxed in the country in which they were accrued. I worked for San Diego County so the US is the only country that can tax those benefits.

And (b) says the exact opposite of what you are stating. You use the term "other Contracting State" by which I assume you are meaning Spain. That statement does not exist in the document from the IRS.

(b) in the treaty is a statement about social security benefits.

Now let me say thank you to all who have shared their experience of being taxed as a US citizen living in Spain. The real life stories are very beneficial. I will not be a tax citizen of Spain in 2022 as I will not be there for more than 183 days (thus still considered a non-resident). But I will in 2023 and hope I remember to come back and let y'all know my experience.


I think you're asking about my reference to an article 20 provision, which I made to clarify that (some) US social security benefits can be taxed by Spain.  It's article 20 that deals with “social security”:

“1. Subject to the provisions of Article 21 (Government Service):
(a) pensions and other similar remuneration derived and beneficially owned by a
resident of a Contracting State in consideration of past employment shall be taxable only in that State; and
   
(b) social security benefits paid by a Contracting State to a resident of the other Contracting State or a citizen of the United States may be taxed in the first-mentioned State.“

If you look at (b), you'll see that the US may tax US social security, but not that “only” the US may tax it.  Contrast this with article 21, which provides that pensions from government employment may only be taxed by the state in which those benefits were earned.  The (b) in article 21 flips this if a resident of the other state is also a citizen (It's because of a similar flipping provision in the US treaty with Italy that I decided not to move there.  I'm an Italian citizen, so my US source government pension would be taxed by Italy.)

So, the treaty deals with government pensions and social security in different articles.  The former is taxed only by one or the other state while the latter may be taxed by the source state, preserving it's taxing authority over those benefits, but doesn't prohibit the other state from also taxing the benefits.

The revelation that social security benefits that derive from contributions while a government employee aren't taxed by Spain (assuming the 21.1(b) clause does not apply) came when I watched a video from htj.tax (sorry for the garbled reference in my earlier post).  Partway through, the Spanish tax guy said something about a guy who paid no Spanish taxes because his income was from a US federal government pension and social security benefits that derived from his US government employment.  So while “social security” benefits can be taxed by Spain under article 20 (because it's silent on the issue), benefits that derive from contributions from government employment salaries seem to fall under article 21.  Maybe that's because of the “subject to the provisions of article 21” clause in article 20.

Anyway, if your retirement income all comes from government employment, article 21 governs and only the US taxes it (so long as you're not a citizen of Spain).  If some portion of your social security is from non-government employment, then article 20 applies to that portion and the US can tax all of it and Spain can tax the non-government portion (but you can use the treaty to get a foreign tax credit, at least).

At least, that's my current understanding.

The obligation to file a federal tax return, even when living abroad, is something which the US government applies to its citizens. It's not Spain's fault!

Spain uses a residence-based tax system, so if you want to be here more than 183 days per year, you will become a Spanish tax resident, and you need to file a return here too. (Well, strictly, not "need to", it's a "legally, should" as many Americans in various low-cost destinations simply chose not to file. I don't recommend this, but I can't say it doesn't happen.)

You can avoid being a Spanish tax resident by spending 182 days or less here. Which you can do by continuing to spend time in USA, or another European country with a more favorable tax regime (e.g. Bulgaria with its 10% flat tax). Indeed, if you get (legal) residence in two EU countries, you can spend less than 182 days in each of them, and hence only be a US taxpayer.

If you can file a USA tax return, I don't expect a Spanish tax return to be very challenging (and you can easily get help if you need it).

Is it worth it? Well... if, for example, you live in a very expensive US state (such as California) and you have a $4,000 pension and a nice house... you probably just about pay your way (as this income is in the lowest 25%), but you don't feel rich. And your nice house has very expensive property taxes for you to pay.

If, instead, you move to Spain, the cost of living is half that of California... and property is maybe a quarter of California real estate. With your Spanish property taxes a small fraction of your California bill. The national minimum wage is just over 1,000 euros, so now your $4,000 looks pretty good (especially as you've got an extra lump of savings given the difference between your USA and Spain properties). For such a benefit (and the much more financially comfortable life that ensues), it seems that filing a Spanish tax return is a small price to pay!

And that's without factoring in the benefit of living in a country with an excellent public health system (and the option of making your contributions to it). For many Americans, Spain's public health system is one of the great delights of living abroad. :-)

Besides, it's mostly an administrative headache, as while you have two tax returns, you don't pay tax twice! There is (a) a DTA (Double Taxation Agreement) between USA and Spain, and (b) the FTC (Foreign Tax Credit) on your US tax return.

There is a helpful IRS publication here:
https://www.irs.gov/pub/irs-pdf/p54.pdf

I'm not a tax accountant or a US taxpayer, so I don't claim any expertise in this area. But I think the FTC applies if you are earning/working in Spain, but doesn't apply to your US-source pension. And the DTA not only provides a way to reclaim (or deduct) foreign paid taxes, but the DTAs often make pensions exempt (per Article 20/21 mentioned by others).

From the above document:
"Pensions and annuities. If you are a U.S. resident, nongovernment pensions and annuities you receive may be exempt from the income tax of treaty countries. Most treaties contain separate provisions for exempting government pensions and annuities from treaty country income tax, and some treaties provide exemption from the treaty country's income tax for social security payments."

Hi..
  Thank you for this valuable information concerning taxation of retirement pensions from US social security. Living in Spain half year and other half in Portugal for a year will probably the best way for me it will at least give me a chance to experience the day to day living for both countries before making the permanent move. 

thanks and best regards to all

Sapin/Portgual are both nice, so that doesn't sound like a terrible way to spend a year. :-)

The Portugal D7 visa seems to be easier to get than Spain's NLV, and seems specifically for overseas retirees. It included a 10-year income tax exemption. El Pais said Portugal was a "paraíso fiscal" for "los jubilados". I think it's going up a bit now (I read 10%), but I am not sure if this has already come into force.

I have a rollover IRA from my 401k that was funded by employment with the state of Alaska. 


The 401k was rolled into into Vanguard when I retired.


This is my largest source of retirement income.


Because it was funded from work by the state are the disbursements of the fund exempt as a public pension?


From what I have read my pension from the state (which is separate and in addition to the IRA) is exempt from Spain taxes though the amount is applied to my income to determine my tax bracket.


With respect to social security: I have read that portion of social security from government employment is also exempt.  I have a mix of public (US government) and private company contributions.  How is that determined?


With respect to Roth...I assume taxes are applied only on distribution s.  My Roth is decades old, how do they divide the distribution between principle and div/int/cap gains.


It's terribly difficult to get a straight answer on these questions.


I will be consulting with an advisor in the near future and will share their thoughts.  In the meantime if anyone has direct experience or knowledge I would appreciate it.


Thanks in advance

One interesting discovery.  My IRA was rolled over from a 401a account not 401k.  A 401a account specifically is made from government employment contributions by both the employer (government) and employee.


It now is a rollover account at a private company.  I'm not sure how to prove the 401a source of the rollover IRA but am working on it.  The transfer took place over 20 years ago so records have been lost during multiple moves during that time period... but I'm working on it.

@chasleslieb


Welcome to the expat.com forum!


This is an older thread, so might be worth posting a new topic.


Best bet for joint filers (USA/Spain) is to work with an attorney/accountant experienced in this area.

@AAV8 Does social security fall under survival???

@conradmilpitas IMO we in the US have been trained to think of taxes as evil and unnecessary.  However, they fund the kinds of things that, for me, make a move to Spain the right choice - good roads, good and affordable health care, high speed rail, etc.  Plus, it's important to weigh the higher taxes against the differences in cost of living. For us, moving from San Francisco to Spain the costs will be significantly lower. For us even with the higher taxes we will still be saving money.

@njtaylor2001 Taxes would be fine if government was efficiently run. The Spanish middle class are very heavily taxed supporting a large number of people working on the black market or not at all. The healthcare system is not as amazing as people on this forum think. Its on the brink of collapse, you will have to wait in line for surgery and to see a specialist, could be a long wait even years. If you do go to hospital, you will need your family bringing you the basics like bottled water, the hospital will not provide it.

@claxnes


Could you please share the name of your accountant in Spain. You are welcome to pm me. Thank you!

@yajubilado

Hi, I read your post with interest and maybe you could help me with so many contradictory information regarding taxes. I will be receiving a pension from the Los Angeles Unified School District and I read that as a public employee I will not be taxed on that in Spain, only in the US. Is that accurate??? I am planning to retire in Spain (so living there more than 183 days) am have dual citizenship (Spain and US). Thanks for your help.

I am still researching this myself so I have no answers at the moment.

Sorry.

@forgabriel

A quick google search says pensions of civil servants are not taxed in Spain but the pension gross  amount is used to determine your progressive tax rate. I did not know this! I am with a large mid west school district and also planning to retire in Spain.

What is the progressive tax rate. Sorry, not too savvy about this.