Advising Americans in Spain: A Compliance Checklist for Wealth Firms

If your firm advises British and European expats in Spain, you may also have American clients, including US citizens, green card holders, and dual nationals.

These clients face reporting requirements in both countries. The US taxes citizens on their worldwide income, while Spain requires tax residents to report certain assets held abroad.

Your firm may not file these forms, but the information you hold can make the process much easier. Here’s what to keep track of, who handles each filing, and where your role ends.

American clients often have financial accounts in both countries, from Spanish bank accounts to US pensions and brokerage accounts. Missing balances or incomplete records can lead to extra work for their accountants and your team.

There’s also a planning opportunity. Some US brokers restrict or close accounts when clients move abroad. Spotting these issues early helps you guide clients through their options.

See our Fidelity guide and our overview of US custodians closing non-resident accounts for more details.

1. Spain: Modelo 720
   Spanish tax residents generally report qualifying foreign bank accounts, investments, insurance, and property when the relevant asset category exceeds €50,000. The filing period is January to March. Subsequent filings may be required when values increase significantly or certain assets are sold, closed, or transferred. For American clients, US assets may fall within these rules.
2. US: FBAR (FinCEN Form 114)
   Required when the combined value of foreign financial accounts exceeds $10,000 at any point during the year. Spanish accounts may count. The deadline is April 15, with an automatic extension to October 15. Accountants need each account’s maximum balance, not just its year-end value.
3. US: Form 8938 (FATCA)
   Americans living abroad may need to report specified foreign financial assets with their US tax return. Thresholds depend on filing status and asset values.
4. Check US broker access
   Confirm whether clients’ US brokerage and retirement accounts have any restrictions because they live abroad, and whether action is needed.
5. Keep one consistent set of figures
   Record each account’s institution, country, owner, year-end value, and maximum balance in its original currency. Consistent records help prevent mismatches between filings.
6. Confirm who files
   Identify the client’s US and Spanish tax advisers, then agree when your firm will provide the information they need.

Unless your firm has the appropriate tax expertise, leave preparing and signing these filings to qualified tax professionals.

Your role is to help ensure the financial picture is complete, including accounts held outside your firm. That same information also supports better pension, investment, and succession planning.

For more detail, see our FBAR and FATCA filing guide.

Aequify brings clients’ accounts across countries into one view, including assets held elsewhere. It also provides tax-ready data packs for accountants, alongside tax outlook and scenario-planning tools to support better client conversations.

See how Aequify works for advice firms

This article provides general information for advisers, not tax or legal advice. Reporting requirements and thresholds can change, so confirm the rules with a qualified tax adviser for each client.