If a person has both U.S. and EU citizenship (say Germany), and is currently living and working in the EU, pay any taxes on income to the U.S.?

Also, apparently no matter what, the person needs to file U.S. tax returns.

1 Answer 1


The United States of America is one of the only countries that taxes based on citizenship, rather than residency. In fact, it might now be the only country that does this. (Eritrea also used to, but I believe that this may have changed.)

This means that if you are a US citizen regardless of where you live in the world, you need to pay (federal) tax to the US government, as well as paying tax to the country where you are resident. You do not need to pay State tax, just Federal tax. And there is a threshold of foreign earnings below which you do not need to pay anything (around $100K per year plus or minus a few thousand).

You DO need to file your tax return every year, even if it is just tell the IRS that you did not earn enough to have to pay federal tax.

  • What are the prospects of U.S. changing the taxation of U.S. citizens living abroad? Is there any pressure or momentum to do that, considering the U.S. is apparently the last country to do so?
    – Make Mark
    Oct 17, 2016 at 4:04
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    I doubt there is much political pressure to change the current system, as people living overseas don't have an awful lot of clout ...
    – Scott Earle
    Oct 17, 2016 at 4:08
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    In addition to filing you also are very likely to need to file a FBAR with the Treasury--and note that not filing that is actually a bigger (and likely more expensive) issue than not filing your tax return. Oct 17, 2016 at 4:23
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    @ValkoSipuli Prospects of US changing taxation of "US persons" residing abroad: virtually nil. Write your congressional representation to protest; see how far that gets you. I don't think the US is the last country to stop taxing its expatriates; it's more like it's the first to start.
    – phoog
    Oct 17, 2016 at 4:50
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    Note that if the country of residence has a tax treaty with the US any double taxation will likely be eliminated in favor of one country or the other, so double taxation is unlikely when the country of residence is European. The trouble is that you still need to file the full US tax return (a complex one at that due to the foreign income and the treaty) and all associated forms even if it is unlikely you'll be taxed. Filing that return is worse than paying the taxes IMO.
    – Dennis
    Oct 17, 2016 at 16:51

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