Droit Fiscal Américain
U.S. Exit Tax and Swiss Occupational Pension Plans (LPP)
Published on: 26/02/2026
Renouncing U.S. citizenship may trigger significant Exit Tax exposure, particularly on Swiss LPP pension capital. Understanding IRC §877A and Covered Expatriate rules is essential for international wealth planning.
U.S. Exit TaxIRC 877ACovered ExpatriateU.S. expatriation taxRenouncing U.S. citizenship taxSwiss LPP pensionSwiss occupational pension U.S. taxForeign pension U.S. taxationDeferred compensation IRC 877AU.S. tax basis foreign pension
