Why U.S. Expats in Europe End Up Building DIY ETF Portfolios

COMING SOON ------- U.S. expats in Europe often avoid local ETFs due to PFIC rules, only to face restricted access to U.S. investments. This article explains why many end up building “DIY ETFs” and the risks involved.

PART OF THE U.S. EXPAT TAX SERIES BY TAX.TRAVEL

2/10/20224 min read

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airplane on sky during golden hour

Part of the U.S. Expat Tax Series by Tax.Travel

This article is part of Antravia’s U.S. Expat Tax Series - a collection of practical guides for Americans living or working abroad. Whether you’re a long-term expat, digital nomad, or remote entrepreneur, these resources explain how to stay compliant with the IRS while reducing double taxation and managing your finances internationally.

Why U.S. Expats in Europe End Up Building “DIY ETFs”

For many U.S. expats, the real investing problem does not start with performance or risk. It starts with access.

Once someone living in Europe understands that most local ETFs are treated as PFICs under U.S. tax law, the obvious response is to stop buying them. That feels sensible. The surprise comes afterwards, when avoiding PFICs does not open up better options, but instead shuts most of them down.

At that point, many expats discover that the issue is no longer just tax. It is structural.

In much of Europe, banks and brokers are increasingly unwilling to deal with U.S. citizens at all. Accounts that were opened years ago may remain open, but investment options become restricted. U.S.-listed ETFs are blocked. U.S.-listed shares are often unavailable. In some cases, trading access is limited to a narrow list of local securities.

This is not driven by European tax law. It is driven by compliance risk. FATCA reporting, U.S. withholding rules, and regulatory exposure make U.S. clients expensive and unattractive for many EU institutions. The result is a quiet form of financial exclusion.

The U.S. tax system then makes that exclusion worse. Local funds are off-limits because of PFIC rules. U.S. funds are inaccessible because of brokerage restrictions. The investor is left with very little room to move.

This is where the idea of a “DIY ETF” appears.

Rather than buying a diversified fund, many U.S. expats in Europe start buying individual European stocks instead. Large, well-known companies feel safer. Holding periods are long. Turnover is low. From a U.S. tax perspective, this works. Ordinary shares in operating companies are not PFICs, and capital gains are taxed in the normal way.

On paper, it looks like a reasonable workaround.

In reality, it is a compromise that few investors would choose if better options were available.

Building diversification stock by stock is difficult. Portfolios become concentrated without meaning to be. Certain sectors dominate because they are more visible or more accessible. Rebalancing is awkward. Decisions that are handled automatically inside a fund suddenly require time, confidence, and discipline.

Over time, risk creeps in quietly, not because the investor is reckless, but because the structure itself is fragile.

Dividend taxation adds another layer of friction. Holding individual European shares means dealing with different withholding regimes, different treaty rates, and different reclaim processes. Foreign tax credits do not always line up neatly with U.S. reporting periods. What would have been invisible inside a fund becomes a recurring administrative task.

Crypto often enters these portfolios for similar reasons. It is accessible. It is portable. It is not a PFIC. From a tax classification standpoint, that is correct. From a portfolio standpoint, it is rarely a substitute for broad equity exposure. It fills a gap that should not exist in the first place.

None of this reflects poor planning or lack of sophistication. It reflects a system that forces ordinary investors into distorted choices.

U.S. tax rules were not designed with long-term overseas residents in mind. European banking systems were not designed to accommodate U.S. regulatory reach. Where those two systems collide, the investor absorbs the cost.

The real lesson is not that U.S. expats should build better DIY portfolios. It is that investment decisions have to be made with the tax and access constraints in mind from the very beginning. Once accounts are opened and products are bought, the menu of options narrows quickly.

At Antravia, we see this pattern repeatedly. People do not end up with these portfolios because they want to. They end up with them because the system leaves them little choice.

Helping U.S. expats understand those constraints early is often far more valuable than fixing the consequences later.

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photo of outer space

Looking for more expat tax guidance? Visit tax.travel/us-expats for detailed resources on filing from abroad, FBAR and FATCA rules, and other essentials for U.S. citizens overseas.

Need help with your U.S. taxes abroad?

Antravia supports American expats, freelancers, and digital nomads with expert tax and accounting guidance. We help you file accurately, claim the right exclusions, and stay compliant wherever you live.

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References

Internal Revenue Service (IRS)
Passive Foreign Investment Companies (PFICs) – definitions, scope, and reporting consequences
https://www.irs.gov/individuals/international-taxpayers/passive-foreign-investment-companies

Internal Revenue Code (26 U.S. Code § 1297)
Statutory definition of a Passive Foreign Investment Company
https://www.law.cornell.edu/uscode/text/26/1297

Internal Revenue Service (IRS)
Form 8621 – Information Return by a Shareholder of a Passive Foreign Investment Company
https://www.irs.gov/forms-pubs/about-form-8621

U.S. Department of the Treasury
Foreign Account Tax Compliance Act (FATCA) – legislative background and compliance framework
https://home.treasury.gov/policy-issues/tax-policy/foreign-account-tax-compliance-act

OECD
Automatic Exchange of Information (AEOI) and international tax transparency context
https://www.oecd.org/tax/transparency/

European Securities and Markets Authority (ESMA)
Investor protection and cross-border investment constraints in the EU
https://www.esma.europa.eu/investor-corner

U.S. Securities and Exchange Commission (SEC)
International investing risks and regulatory differences for U.S. investors
https://www.investor.gov/introduction-investing/general-resources/news-alerts/alerts-bulletins/international-investing

Internal Revenue Service (IRS)
Foreign tax credit rules relevant to dividend withholding on non-U.S. equities
https://www.irs.gov/forms-pubs/about-form-1116

Disclaimer:
Content published by Antravia is provided for informational purposes only and reflects research, industry analysis, and our professional perspective. It does not constitute legal, tax, or accounting advice. Regulations vary by jurisdiction, and individual circumstances differ. Readers should seek advice from a qualified professional before making decisions that could affect their business.
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