Do I Pay Taxes in Both Countries as a Dual Citizen?
- Do I Have to File U.S. Taxes as a Dual Citizen?
- Why Don't Most Dual Citizens Owe U.S. Taxes?
- How Do I Avoid Double Taxation as a Dual Citizen?
- What Tax Strategy Should I Use for My Situation?
- How Do I File My Taxes as a Dual Citizen?
- What If I Just Discovered I'm an Accidental American?
- What Challenges Do Dual Citizens Face When Filing?
- Can I Use Both FEIE and FTC on the Same Tax Return?
- What If I'm Behind on Filing My U.S. Taxes?
- Do I Lose U.S. Benefits If I Use Foreign Tax Credits?
- What Are My Next Steps as a Dual Citizen?
- Get Expert Help with Your Dual Citizen Taxes
While dual citizens must file U.S. tax returns on worldwide income, most end up owing nothing to the IRS. According to IRS data analyzed across six years (2016-2021), nearly two out of three American expats owe zero U.S. taxes after applying available protections. The U.S. tax system provides powerful tools to eliminate double taxation for dual citizens living abroad.
As a dual citizen, you face a unique set of circumstances. The U.S. taxes your worldwide income based on citizenship, while your country of residence likely taxes you based on where you live. This creates the potential for paying taxes twice on the same income. But here’s what matters: Between the Foreign Earned Income Exclusion (up to $130,000), the Foreign Tax Credit, and tax treaties with over 60 countries, the vast majority of dual citizens can reduce their U.S. tax bill to zero while staying fully compliant.
This guide explains how dual citizenship affects your taxes, the protections in place to prevent double taxation, and the correct filing procedures for both countries.
Do I Have to File U.S. Taxes as a Dual Citizen?
Yes, all U.S. citizens must file U.S. tax returns regardless of their second citizenship or where they live. The United States uses citizenship-based taxation, meaning the IRS requires you to report your worldwide income even if you’ve never lived in the U.S. or hold dual citizenship with another country.
You must file a U.S. tax return if your income exceeds these thresholds for tax year 2025 (filed in 2026):
- Single or Married Filing Separately: $15,750
- Married Filing Jointly: $31,500
- Head of Household: $23,625
You must file even when you expect to owe nothing after applying exclusions and credits. Your country of residence also has its own filing requirements, which typically require you to report income because you live there.
The difference sounds overwhelming, but it rarely means paying taxes twice.
Dual citizenship creates unique tax situations. We’ll help you sort through them.
Why Don’t Most Dual Citizens Owe U.S. Taxes?
While you file in both countries, you almost never pay full taxes to both. Here’s why dual citizenship rarely results in double taxation:
Powerful U.S. Protections Against Double Taxation
The U.S. provides three primary tools specifically designed to prevent dual citizens from paying taxes twice on the same income: the Foreign Earned Income Exclusion, Foreign Tax Credit, and international tax treaties.
Tax Treaties Provide Additional Relief
The U.S. has income tax treaties with over 60 countries that determine which country has primary taxing rights for specific types of income. While most treaties contain “saving clauses” preserving the U.S.’s right to tax its citizens, the exclusions and credits available to Americans abroad typically eliminate any U.S. tax liability.
How Do I Avoid Double Taxation as a Dual Citizen?
The U.S. provides three main protections that work together to eliminate double taxation for dual citizens:
Foreign Earned Income Exclusion (FEIE)
The FEIE allows you to exclude up to $130,000 of foreign-earned income from U.S. taxation (for tax year 2025, filed in 2026). For tax year 2026 (filed in 2027), this amount increases to $132,900.
Who qualifies:
- Physical Presence Test: Present in foreign countries for 330+ days in any 12-month period
- Bona Fide Residence Test: Legal resident of a foreign country for an entire tax year
Example: Low-Tax Country
Sofia, a dual US-Italian citizen living in Rome, earns €85,000 ($93,500) working for an Italian company. She meets the Physical Presence Test and can exclude the entire amount using the FEIE, owing $0 in U.S. taxes.
Married couples: Each spouse can claim the full exclusion, potentially excluding up to $260,000 combined.
Best for: Dual citizens in low-tax countries or those earning under the exclusion limit.
Foreign Tax Credit (FTC)
The FTC provides a dollar-for-dollar credit for income taxes paid to foreign governments.
When to use it:
- You live in a high-tax country
- Your income exceeds the FEIE limit
- You have significant passive income (dividends, interest, rental income)
Example: High-Tax Country
David, a dual US-German citizen, earns $150,000 in Germany and pays $48,000 in German taxes. He uses the Foreign Tax Credit to offset his entire U.S. tax liability, owing $0 to the IRS.
Best for: Dual citizens in high-tax countries where foreign taxes paid exceed or equal potential U.S. tax liability.
Tax Treaties
U.S. tax treaties determine which country has primary taxing rights for specific income types.
Common treaty benefits:
- Reduced withholding rates on dividends and interest
- Exemptions for certain income types
- Tie-breaker rules for dual residents
Most treaties contain “saving clauses” preserving the U.S.’s right to tax its citizens. However, when combined with FEIE and FTC, these protections typically eliminate U.S. tax liability entirely.
What Tax Strategy Should I Use for My Situation?
Your optimal tax strategy depends on your specific circumstances:
Use FEIE If You:
- Live in a low-tax country (like the UAE, Panama, or Costa Rica)
- Earn under $130,000 in earned income
- Want to preserve credits for future use
Use FTC If You:
- Live in a high-tax country (like Sweden, France, or the UK)
- Earn above the FEIE limit
- Have significant passive income
Use Both If You:
- Have earned income (use FEIE) plus passive income (use FTC)
- Earn more than the FEIE limit and pay foreign taxes
Example: Mixed Strategy
Lisa, a dual US-Canadian citizen in Toronto, earns $95,000 in salary and $25,000 in investment income. She uses FEIE for her salary and FTC for the investment income, owing $0 in U.S. taxes after accounting for the Canadian taxes she has paid.
How Do I File My Taxes as a Dual Citizen?
Filing as a dual citizen involves coordination between two tax systems:
Step 1: File Your U.S. Return
Required U.S. forms include:
- Form 1040: Your primary U.S. tax return
- Form 2555: To claim the FEIE
- Form 1116: To claim the FTC
- FinCEN Form 114 (FBAR): If foreign accounts exceed $10,000 total
- Form 8938 (FATCA): If foreign assets exceed specific thresholds
U.S. expats automatically get until June 15 to file (extended from April 15), with additional extensions available to October 15.
Step 2: File in Your Country of Residence
Follow local tax laws and deadlines, which vary by country. For dual citizens in Canada, see our US-Canada dual filing guide. For those in the UK, see our US-UK dual citizen tax guide.
Step 3: Coordinate Between Countries
- Convert foreign income using IRS-approved exchange rates
- Apply treaty benefits where applicable
- Keep detailed records of all foreign taxes paid
- Avoid double-claiming the same credits
What If I Just Discovered I’m an Accidental American?
If you acquired U.S. citizenship at birth but have minimal connection to the U.S., you’re still subject to U.S. tax obligations. Many dual citizens discover their U.S. filing requirements only when:
- Opening bank accounts (banks report to the IRS under FATCA)
- Selling property
- Receiving an inheritance
The good news: Streamlined Filing Compliance Procedures help you catch up without penalties if your failure to file was non-willful. Most Accidental Americans we work with discover they owe little or nothing after applying available protections.
What Challenges Do Dual Citizens Face When Filing?
Different Tax Years
Your residence country may use a different tax year than the U.S. Working with professionals familiar with both systems helps align reporting and avoid timing issues.
Complex Income Types
Business income, foreign rental property, investments, and retirement accounts complicate dual filing. Professional guidance ensures proper treatment under both tax systems.
State Tax Obligations
Some U.S. states continue to tax former residents living abroad. Understand your state residency rules and consider severing ties properly before moving abroad.
Foreign Account Reporting
FBAR and FATCA reporting requirements catch many dual citizens by surprise. Missing these can trigger significant penalties, even if you owe no tax.
Can I Use Both FEIE and FTC on the Same Tax Return?
Yes, but NOT on the same income. You can:
- Use FEIE for earned income and FTC for passive income
- Use FEIE up to the limit and FTC for excess earned income
- Switch strategies year to year based on changing circumstances
Many dual citizens benefit from reviewing their strategy annually to optimize tax savings.
What If I’m Behind on Filing My U.S. Taxes?
If you’re behind on U.S. tax filing, don’t panic. The Streamlined Filing Compliance Procedures help non-compliant taxpayers catch up without penalties if their failure to file was non-willful.
You’ll need to file:
- Three years of delinquent tax returns
- Six years of FBARs
- A certification that your failure to file was non-willful
Most dual citizens discover they owe little or nothing once proper protections are applied. The key is to act before the IRS contacts you.
Do I Lose U.S. Benefits If I Use Foreign Tax Credits?
No. Using legitimate tax benefits doesn’t affect your U.S. citizenship rights or access to consular services. Claiming FEIE or FTC reduces your U.S. tax liability while keeping you compliant with U.S. tax law.
What Are My Next Steps as a Dual Citizen?
- If you’re newly discovering your U.S. tax obligations: Start by determining your filing requirements and which protection (FEIE or FTC) best fits your situation. Most situations are more manageable than they initially appear.
- If you’re currently filing: Review whether you’re using the optimal strategy. Many dual citizens reduce their tax burden by switching between FEIE and FTC based on changing circumstances.
- If you’re behind on filing: Act now to use Streamlined Procedures while available. Most dual citizens discover they owe little or nothing and can catch up penalty-free.
Get Expert Help with Your Dual Citizen Taxes
Greenback is an American company founded in 2009 by U.S. expats for expats. We’ve helped over 23,000 expats file more than 71,000 returns while maintaining a 4.9-star average across 1,200+ TrustPilot reviews. Many of our CPAs and Enrolled Agents are expats themselves, living in 14 time zones, and they have the knowledge and patience to help you file correctly in both countries.
No matter how late, messy, or complex your return may be, we can help. You’ll have peace of mind, knowing that your taxes were done right in both countries.
If you’re ready to be matched with a Greenback accountant, click the get started button below. For general questions on expat taxes or working with Greenback, contact our Customer Champions.
Two passports. One clear tax plan.
This article is intended for informational purposes and does not constitute tax or legal advice. Tax situations vary widely, and you should consult with a qualified tax professional regarding your specific circumstances.
