US expats living in Portugal, France, Germany, Spain, Italy, the Netherlands, Ireland, Switzerland or the UAE frequently arrive at the same point after a few years abroad: several IRAs, opened at different life stages, sitting at different custodians, each with an increasingly complicated view of what a client with a European or Middle Eastern address is allowed to do.
A rollover IRA from a 401(k) left behind at a former US employer, a rollover we have written about in our 401(k) to IRA rollover guide. A Traditional IRA funded before the move. Perhaps a Roth IRA from an earlier period of eligibility. Possibly a SEP IRA from years of self-employment or consulting. This guide explains why that patchwork becomes a genuine risk once you are living abroad, how EU rules compound the standard US expat brokerage restrictions, and how a properly sequenced consolidation protects your retirement savings.
Where do your IRAs stand in Portugal, France, Spain or the UAE?
Custodian access and tax treatment differ in each. One review tells you where you stand from where you actually live.
Key Takeaways
- US brokerages restrict expat accounts for two separate reasons: general non-resident policy, which affects expats everywhere, and EU product documentation rules, which affect clients specifically resident in the EU and the wider European Economic Area.
- Vanguard is widely reported as the most restrictive of the major US custodians for non-resident clients. Fidelity is commonly reported to block new mutual fund purchases while preserving existing holdings. Schwab International and Interactive Brokers are generally the most accommodating for US citizens living abroad. These are reported market patterns, not published guarantees, and they change.
- Buying non-US mutual funds or ETFs to work around a restricted US account creates Passive Foreign Investment Company exposure, which is the opposite of what a consolidation should achieve.
- Portugal, France, Germany, Spain, Italy, the Netherlands, Ireland, Switzerland and the UAE each treat IRA income differently under domestic law and under the relevant treaty, so a consolidation plan has to be built around your specific country of residence.
- Cameron James USA advisers are SEC authorized. For advice to a US citizen on US-registered retirement accounts, non-US regulatory permissions are not the relevant standing.
Why the Provider Problem Is Sharper in Europe and the Middle East
Every US expat, wherever they go, runs into the general reality that US brokerages have been reducing their appetite for non-resident clients since FATCA came into force. What is specific to expats resident in the EU is a second and separate layer of rules.
It is worth being precise about which rule does the work here, because the two are routinely conflated. The requirement for a Key Information Document comes from the EU PRIIPs Regulation, Regulation (EU) No 1286/2014, which requires a KID for packaged retail investment products made available to retail investors in the European Economic Area. MiFID II is the surrounding investor-protection framework covering product governance, suitability and client categorization. Very few US-domiciled ETFs and mutual funds have ever produced a KID, so an EU-resident retail client cannot buy them. Schwab sets out the PRIIPs position on its own international site here. Charles Schwab told clients that from 19 September 2019, clients resident in the EU could no longer purchase US-registered exchange-traded funds or exchange-traded notes, while existing positions could be retained. Several US custodians went further and withdrew from retail brokerage for clients resident in some EU countries in the early 2020s.
There is one route around the documentation problem, and it is narrow. A client who is categorized as an elective professional client under MiFID II falls outside the retail protections that trigger the KID requirement. That categorization depends on meeting quantitative and qualitative tests set by the firm, and most retail investors will not meet them. It should be treated as an exception, not a plan.
The practical result is that a US expat living in France or Germany can face tighter restrictions than one living in the UAE, where the EU rules do not apply, even though both are equally living abroad from the perspective of the custodian.
| Provider | General expat posture | Practical effect for residents of Europe and the Middle East |
| Vanguard | Most restrictive of the large custodians | Widely reported to restrict trading, block new purchases or close accounts for clients with a non-US address, whether in the EU or elsewhere |
| Fidelity | Moderate restriction | Existing IRA holdings and ETF trading commonly remain accessible, while new mutual fund purchases are frequently blocked for non-residents |
| Charles Schwab | Mixed by region | Schwab International serves many non-resident US citizens, but retail brokerage has been withdrawn in a number of EU jurisdictions, so availability depends on the specific country |
| Interactive Brokers | Built for cross-border clients | Holds both US and EU regulatory standing, which allows it to keep serving US citizens resident in the EU without the documentation conflict that affects US-only brokerages |
| Merrill, Morgan Stanley, UBS | Typically close or force a transfer | Full-service US wealth platforms have generally exited the non-resident retail market |
| TIAA | Retirement access retained, brokerage restricted | Core retirement account functionality tends to continue, while wider brokerage services are more commonly limited |
Table: reported custodian posture toward non-resident clients. These are patterns reported by advisers and clients rather than published policies, they vary by country within the EU, and they change without much notice. Treat the table as a starting point for due diligence and confirm your own position with each institution in writing.
The structural point survives every policy change: the longer you wait to review custodian access, the fewer options you are likely to have when a restriction notice eventually arrives.
Rolling Over a 401(k) When You Already Live Abroad
Most people arrive at this subject through a single event rather than through a tidy-up. You leave a US employer, or the employer is acquired, or the plan changes administrator, and a letter arrives asking what you want done with the balance. The complication is that you are no longer in the United States when the question is asked, and the two obvious answers both behave differently from abroad than they do at home.
Leaving it in the plan, or rolling it to an IRA
Leaving the balance in the plan is often presented as the do-nothing option, and for some people it is reasonable. The charges may be institutional and lower than retail, and the plan is a US-domiciled arrangement that raises no local product questions in your country of residence. The limitations tend to show up later. Plan investment menus are short and chosen for a US-resident workforce. Many plans are inflexible about partial withdrawals, which matters when you are trying to shape income around a treaty position. Plans can be restrictive about foreign addresses and non-US bank details for distributions, and small balances can be cashed out involuntarily under the plan rules, which is the worst outcome of all because it is a distribution you did not choose and did not time.
An IRA generally gives you the control the plan will not: a full investment universe, flexibility over the size and timing of withdrawals, and, decisively for someone living outside the United States, a choice of custodian. That last point is the one this article exists to make. From abroad, the binding constraint is usually not tax and not investment selection. It is whether a custodian will keep servicing an account registered to your address, which is exactly the problem set out in the sections above. Rolling a 401(k) into an IRA at a custodian that later restricts you simply moves the problem, so the destination decision should be made at the same time as the rollover decision rather than after it.
The one sequencing point that can be expensive to get wrong
There is a narrow but serious exception, and it applies if you are a green card holder who may hand the card back, or a citizen who may renounce. For someone going through expatriation, a 401(k) and an IRA are not treated the same way. A qualified employer plan can fall to be treated as eligible deferred compensation, whereas an IRA is a specified tax deferred account, and a specified tax deferred account is deemed distributed in full on the day before expatriation with no exclusion available against it. Rolling the plan into an IRA first can therefore convert a manageable position into a fully taxable one, purely because of the order in which two steps were taken.
Two things follow. First, if expatriation is genuinely on your horizon, do not roll the plan into an IRA until that has been thought through with a CPA or Enrolled Agent, because this is US tax planning and it is not something we set out to advise on. Second, and this is the part most guides get wrong, the 401(k) is not therefore your permanent home. The classification only matters as a snapshot for the exit tax computation on one date. Once that date has passed, rolling to an IRA is usually the better long-term answer for all the reasons in the previous section.
If you are UK resident, the mechanics of the rollover itself are set out step by step in our 401(k) to IRA rollover guide for UK residents. The principles carry across to the rest of Europe and to the Gulf, but the treaty analysis in that guide is UK specific, so read it for process rather than for your own tax position if you live elsewhere.
The PFIC Trap: Why Just Open a Local Account Is the Wrong Answer
Faced with a restricted US brokerage, the instinctive reaction is often to open an account with a local European or Gulf bank or investment platform instead. For a US citizen this is usually the worst available option. Under US tax law, most non-US mutual funds and many non-US domiciled ETFs are treated as Passive Foreign Investment Companies. Under the default Section 1291 excess distribution regime, gains and certain distributions can be taxed at the highest ordinary income rate applicable in the years to which they are allocated, with an interest charge added, and each fund generally requires its own Form 8621 for each year. The IRS publishes the instructions to Form 8621. The elections that improve this treatment, the qualified electing fund election in particular, depend on the fund providing annual information that most European funds do not produce for US investors.
This is a materially different question from PFIC exposure inside a UK SIPP. There, a reporting exception applies to PFIC interests held through an arrangement treated as a foreign pension fund under an income tax treaty where the treaty defers taxation until benefits are paid, which is set out in the regulations under section 1298(f) and can be read in the Code of Federal Regulations. IRAs held with a US custodian and invested in US-domiciled funds do not raise PFIC issues in the ordinary course. The risk arises only when restricted access pushes an expat toward locally domiciled investment products as a workaround. A consolidation plan should keep you inside US-domiciled holdings, not move you out of them.
A Note From Jonathan Laws
Traditional IRA and Roth IRA When Consolidating
A Traditional IRA and a Roth IRA are not interchangeable. Consolidating scattered accounts should generally produce two simplified holdings, one bringing together every Traditional and rollover IRA and one bringing together every Roth IRA, rather than a single blended account. Moving Traditional money into a Roth is a conversion, and a conversion is a US taxable event in the year it happens, so it should be a deliberate decision taken on its own merits rather than an accidental side effect of tidying up old accounts.
| Traditional IRA | Roth IRA | |
| US tax on distributions | Taxed as ordinary income when withdrawn | Generally free of US tax once the qualified conditions are met |
| Local country tax treatment | Varies significantly. Portugal, France, Germany, Spain, Italy, the Netherlands, Ireland, Switzerland and the UAE each apply different domestic rules and treaty positions | Roth status is often not recognized automatically by the country of residence, so country-specific advice is essential |
| Can it be merged with the other type | Can be consolidated with other Traditional and rollover IRAs | Can be consolidated with other Roth IRAs only |
| Required minimum distributions | Begin at age 73 for those who reach age 72 after 31 December 2022, rising to age 75 for those who reach age 73 after 31 December 2032 | None during the lifetime of the original owner. Inherited accounts are treated differently |
| Effect of a conversion | Amounts converted out are added to US taxable income in the year of conversion | Receives the converted amount, after the US tax on the conversion has been accounted for |
Table: the two account types compared for consolidation purposes. The required minimum distribution ages reflect the SECURE 2.0 changes summarized in the Congressional Research Service note on RMD rules.
One point that catches expats out
Conversion income is not earned income, so the Foreign Earned Income Exclusion does not shelter it. An expat who excludes all foreign salary can still face a full US tax bill on a Roth conversion. The reverse is also true and is the reason conversions are worth modeling: a year with little or no other US taxable income can be a comparatively cheap year in which to convert. That is a planning exercise, not a rule of thumb, and it needs to be run alongside the tax position in your country of residence.
Country Considerations Across Europe and the Middle East
Portugal
Portugal remains the leading European destination in the Cameron James USA client base, and it is also the jurisdiction where the position has changed most. The Non-Habitual Resident regime closed to new applicants, with transitional rules for people who were already mid-relocation, and existing holders keep their benefits for the remainder of their ten-year period. The replacement regime, the Tax Incentive for Scientific Research and Innovation, known as IFICI and sometimes marketed as NHR 2.0, was introduced with effect from 1 January 2024. It gives a 20 percent flat rate on qualifying Portuguese-source employment and self-employment income for ten years, together with an exemption for most categories of foreign-source income. The critical detail for anyone reading this guide is that the exemption for foreign-source income under IFICI does not extend to pensions, and the regime is gated on working in a qualifying activity, which most retirees will not satisfy. The International Bar Association summary of the regime is here.
Two honest caveats. First, published sources disagree: most commentary, including the International Bar Association overview from April 2025 and Portuguese legal commentary from November 2025, states that pensions are excluded from the IFICI foreign-income exemption and are taxed at progressive rates, while at least one 2026 online guide asserts that a separate 10 percent flat rate applies to qualifying retirees. We regard the first reading as the better supported one, and we would not plan around the second without confirmation from a Portuguese tax adviser. Second, whether an IRA distribution is characterized as a pension at all for Portuguese purposes is a separate question that turns on the type of account and the treaty article applied. Timing a consolidation, and any conversion, around a Portuguese arrival or departure date has real financial consequences, and it is not a decision to take from a website.
France, Germany, Spain and Italy
Each of these jurisdictions characterizes US pension and IRA income under its own domestic rules, and each interacts differently with the relevant US tax treaty. The EU documentation restrictions on US brokerages tend to bite hardest for long-term residents of these four countries, which makes early consolidation onto a custodian that can lawfully serve an EU-resident client a practical priority alongside the tax analysis.
The Netherlands and Ireland
Both countries have long-standing US tax treaties with specific pension articles, but neither automatically extends to Roth IRA growth the tax-free treatment that applies in the United States. As with the United Kingdom, the headline US benefit of a Roth does not travel unmodified across the Atlantic, and the point should be settled before a conversion rather than after it.
Switzerland
Switzerland sits outside the EU, so the EU product documentation rules do not apply directly. Swiss banking and brokerage compliance requirements bring their own restrictions for US-connected accounts, a legacy of how Switzerland implemented FATCA, so the practical outcome can still be a narrowed set of custodian options.
The United Arab Emirates and the wider Gulf
The UAE does not levy personal income tax on employment income, which removes one layer of complexity. It removes nothing on the US side. Your US filing obligations continue, FBAR and FATCA reporting continue, and the underlying custodian access issue continues. Because the UAE sits outside the EU framework, expats there are less likely to meet the specific European documentation restrictions, but they remain fully exposed to the general non-resident policies applied by Vanguard, Fidelity and similar large custodians.
A Practical Consolidation Sequence
- Inventory every IRA you hold: type, custodian, current restriction status and approximate value.
- Identify which of your existing custodians remain workable from your specific country of residence. This differs between an EU resident and a UAE resident.
- Select a target custodian, typically one with both US and relevant non-US regulatory standing, such as Interactive Brokers, or Schwab International where it is still available in your jurisdiction.
- Move the money by trustee-to-trustee transfer within each IRA type, Traditional to Traditional and Roth to Roth, so that nothing is treated as a distribution. This is worth doing precisely: the IRS confirms that a direct transfer from one IRA trustee to another is not a rollover, following Revenue Ruling 78-406, which means the one-rollover-per-twelve-months limit does not apply to it. Guidance is on the IRS rollovers page. A 60-day indirect rollover, by contrast, is subject to that limit and to withholding risk.
- Confirm the underlying holdings remain US-domiciled funds, so that consolidation does not walk you into PFIC territory.
- Reassess your country-specific tax position, your required minimum distribution planning and any conversion strategy once the accounts are consolidated and simplified.
One point on cost, because it changes the arithmetic on whether a review is worth doing. Cameron James USA does not charge an initial advice fee on US-connected investments or US retirement accounts, so establishing whether consolidation improves your position does not itself carry a fee. Ongoing advice, custodian and fund charges still apply and are published in full.
Can You Still Contribute While Living Abroad?
Sometimes, and it turns on how your income is treated for US purposes rather than on where you live. A contribution requires taxable compensation, and income excluded under the Foreign Earned Income Exclusion is not taxable compensation for this purpose. An expat who excludes all foreign salary therefore has nothing left to contribute from. Two situations commonly preserve eligibility: earnings above the exclusion limit, and compensation for work physically performed in the United States. Claiming the Foreign Tax Credit instead of the exclusion leaves the income in the US tax base and can therefore preserve eligibility, which is one of several reasons the choice between the two methods deserves a proper calculation rather than a default.
For 2026 the IRS has set the IRA contribution limit at 7,500 US dollars, announced in this news release, with an additional catch-up contribution of 1,100 US dollars for those aged 50 and over, published on the IRS catch-up contributions page, giving a combined 8,600 US dollars. That single limit applies across all of your IRAs together, Traditional and Roth combined, not to each account separately.
Speak to a cross-border adviser about your US retirement accounts
If you are holding several old IRAs and are unsure which can still be serviced from your country of residence, one conversation will tell you what you have, what is at risk and what to consolidate first.
Frequently Asked Questions
Why does my brokerage treat me differently in Europe than a friend of mine in the UAE?
EU residency brings the EU PRIIPs and MiFID II framework into play, which requires EU-compliant documentation for many investment products. Because very few US-domiciled funds carry that documentation, several US brokerages restrict EU-resident clients specifically, separately from their general non-resident policies. The UAE sits outside that framework, so restrictions there tend to follow the more general non-resident pattern.
Is it safe to open a local investment account instead of keeping my US IRA?
An IRA itself has to remain with a US custodian. It cannot be replicated at a local European or Gulf bank. The risk described in this guide relates to taxable investment accounts outside the IRA wrapper, where local mutual funds and ETFs can bring PFIC treatment. Within the IRA, the priority is finding a custodian that will keep serving you, not switching to local products.
Can I still contribute to an IRA while living in Portugal, France or the UAE?
It depends on how your income is treated for US tax purposes. Using the Foreign Earned Income Exclusion can reduce your taxable compensation below the level needed to support a contribution. Using the Foreign Tax Credit instead can, in some cases, preserve eligibility. The calculation is specific to your country and your income.
Does moving my IRAs to Interactive Brokers or Schwab trigger US tax?
A trustee-to-trustee transfer between IRAs of the same type is not a taxable event, and the IRS treats it as a transfer rather than a rollover, so the one-rollover-per-twelve-months limit does not apply. Converting a Traditional IRA to a Roth IRA is a separate and taxable transaction and should be evaluated independently of a straightforward consolidation.
Will consolidating change my required minimum distributions?
Consolidating does not remove an RMD obligation, but it makes it easier to manage. Traditional IRA required minimum distributions are calculated across your accounts and can be satisfied from any one of them, so fewer accounts means fewer moving parts and less risk of missing a distribution. A Roth IRA has no required distributions during the lifetime of the original owner.
Can Cameron James USA advise me wherever I live in Europe or the Middle East?
Cameron James USA advisers are SEC authorized, which is the relevant standing for advising US citizens on US-registered retirement accounts, wherever the client is resident. Non-US regulatory permissions, including FCA or EU authorizations, are not the standing that governs this type of advice.
Related Articles
These are existing Cameron James USA articles covering the questions that come up most often alongside an IRA consolidation.
401(k) to IRA Rollover for a UK Resident: Transfer Guide 2026
The rollover mechanics in detail for a UK-resident client. Process applies more widely; the treaty analysis in it does not. For a client outside the United States. The sequencing and custodian questions are the same ones this guide raises for residents of Europe and the Gulf.
Vanguard UK Closed Your Account Because You Live in the US? Here Is What to Do
A worked example of a large custodian withdrawing service over residency, and how to respond without damaging the tax position.
UK State Pension for US Residents: Tax, the NT Code and Buying Back Years
State pension entitlement, buying back missing years, and how the NT code works. Relevant to anyone sequencing several retirement income sources.
STM Malta QROPS and the Buzzacott Memo: What the May 2026 US Tax Notice Means for Cross-Border Members
The foreign trust reporting question in detail, for readers who also hold a non-US pension arrangement alongside their IRAs.
STM Malta QROPS and US Compliance: What the Buzzacott and ICTS Memoranda Say, and Where They Differ
Two professional opinions on the same structure, and how we read the difference between them.
Prudential Personal Pension for Non-UK Residents: Accessing Your Pension from Abroad
How legacy provider restrictions play out for a client living outside the country where the account sits.
Disclaimer: Some of the content of this communication was provided by third parties of Cameron James USA. We have not verified the information contained herein, but we believe the content is reliable. None of this content should be construed as legal, accounting or tax advice. Many legal issues, accounting or tax regulations are complex and often have highly-individualized requirements, you should seek the advice of a competent professional if you have specific questions.
Jonathan Laws, ACA Ch.FCSI, Senior Independent Financial Adviser, Cameron James
“The clients who reach me on this subject are rarely in trouble yet. They have three or four IRAs, everything technically works, and the only symptom is a vague sense that the accounts have become harder to deal with since the move. Then a letter arrives from one custodian, and suddenly the decision is being made on a timetable set by somebody else. Consolidation is much easier to do calmly, in a year of your choosing, than in the six weeks a restriction notice tends to give you.
The mistake I most want to head off is the local account. It feels like the obvious fix when a US platform stops cooperating, and for a US citizen it is usually the most expensive thing you can do, because local funds bring the PFIC regime with them. The right instinct is the opposite of intuitive: stay inside US-domiciled holdings, and change the custodian rather than the investments.”