Author Topic: Retire to the EU - Dual Citizenship Residency and Health Insurance Questions  (Read 4768 times)

Threshkin

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We are a few months away from FIRE and are investigating options for a retirement destination and have been considering the EU as an option.  But we are having trouble finding information on residency and health insurance costs for our situation.  My DW is a naturalized German citizen and I am a US citizen.

Most of the information I can find on retiring to Europe is aimed at US citizens.  This is understandable but is not as helpful for us.  Can anyone here help or point me at resources that can answer our questions?

Here are some of the things we would like to know:

  • Does EU citizenship for one half of a married couple simplify the residency process for the couple?
  • Are there different health insurance options for EU citizens (and their spouses) vs. US citizens?  Note: We most likely would not live in Germany.
  • As a naturalized German citizen can my DW get dual citizenship for the US?  Her ex told her no but he is not a trustworthy source.

We have enough assets to meet the solvency requirements for retirees so we are not worried about that aspect

Thanks!

Paul der Krake

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The EU is not an homogeneous block. The health insurance coverage is completely different from country to country. You need to look at the laws for a specific country.

That being said:
Does EU citizenship for one half of a married couple simplify the residency process for the couple?
Yes.

Threshkin

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Thanks Paul.  We have been looking at insurance on a country by country basis.  My question was more "Is there any difference in the insurance options available for in a given country for EU vs. US citizens?"  Or is the information we find for US citizens applicable?

The EU is not an homogeneous block. The health insurance coverage is completely different from country to country. You need to look at the laws for a specific country.

That being said:
Does EU citizenship for one half of a married couple simplify the residency process for the couple?
Yes.

former player

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Thanks Paul.  We have been looking at insurance on a country by country basis.  My question was more "Is there any difference in the insurance options available for in a given country for EU vs. US citizens?"  Or is the information we find for US citizens applicable?

The EU is not an homogeneous block. The health insurance coverage is completely different from country to country. You need to look at the laws for a specific country.

That being said:
Does EU citizenship for one half of a married couple simplify the residency process for the couple?
Yes.
Health insurance and state health provision come under "services", which is one of the four fundamental freedoms (work, goods, services, capital) of the EU.  DW is entitled to state health provision and the purchase of health insurance in any EU country on exactly the same terms as a national of that country, with no discrimination or differential.  (That's the theory.  Of course, if you are unfamiliar with the language, laws and culture of a country those are barriers you will need to work through).  As DW's spouse you have the same rights as DW.  Your US citizenship becomes irrelevant: you exercise your rights through DW's EU citizenship.

jim555

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The UK has the NHS for people who are "ordinarily resident" as the only requirement.  Each EU country has its own rules.

Playing with Fire UK

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  • As a naturalized German citizen can my DW get dual citizenship for the US?  Her ex told her no but he is not a trustworthy source.

Think carefully about whether you would want to do this. As a US citizen you will be taxed by the US wherever you live (or have to file tax returns even when there is no tax to pay) in addition to the tax you need to pay based on your residency. As an EU citizen you won't get taxed twice within the EU, and there can be some favourable situations where you escape the tax entirely. You and your spouse may be able to take advantage of this by thinking about in whose name you hold various investments.

Healthcare provision in many European countries works differently to the US. Many have more state involvement than you will be used to (and where there is a requirement to pay for health insurance this pay be collected as a tax by the government based on income rather than risk).

Try this http://ec.europa.eu/social/main.jsp?catId=858&langId=en for the countries you are thinking about living in.

Threshkin

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  • As a naturalized German citizen can my DW get dual citizenship for the US?  Her ex told her no but he is not a trustworthy source.

Think carefully about whether you would want to do this. As a US citizen you will be taxed by the US wherever you live (or have to file tax returns even when there is no tax to pay) in addition to the tax you need to pay based on your residency. As an EU citizen you won't get taxed twice within the EU, and there can be some favourable situations where you escape the tax entirely. You and your spouse may be able to take advantage of this by thinking about in whose name you hold various investments.

Healthcare provision in many European countries works differently to the US. Many have more state involvement than you will be used to (and where there is a requirement to pay for health insurance this pay be collected as a tax by the government based on income rather than risk).

Try this http://ec.europa.eu/social/main.jsp?catId=858&langId=en for the countries you are thinking about living in.

Thanks!  This is a very useful site.  I need to think about the tax implications as well.  Complicated!  It makes my head spin.  I understand why people end up paying an agent to assist them. 

FrugalZony

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Well the tax consequence already applies as a green card holder, unless she's willing to give up her GC once you move.
But you, as a USC, will still be taxable with your world income in the US no matter where you live.
If both of you live in the US right now, I suppose your wife holds a gc?

Assuming your wife qualifies for US citizenship (check USCIS website for eligibility info https://www.uscis.gov/sites/default/files/files/article/chapter4.pdf)
If your wife wants to be a DUAL citizen, she needs to apply for a "Beibehaltungsgenehmigung" first BEFORE doing anything on the US side.
If she just applies for US citizenship without receiving this BBG, she'll loose the German citizenship.
Here's more reading on that on the official German site:
http://www.germany.info/Vertretung/usa/de/05__Dienstleistungen/02__Staatsangehoerigkeit/02__Beibehaltung/__Beibehaltung.html

There's also tons of resources online, including  Yahoo and FB groups, where people, who have gone through the processes (both BBG and USC) help each other out with tips
and sample documents etc.
Feel free to message me if you you want links, I know several folks who have gone through these recently. I'm sure they'd be happy to give her pointers.

As others have said, the EU is a huge patchwork of countries with very different health systems and other circumstances, so it's hard to give specific advice unless you narrow it down to a couple of countries that you are considering.
« Last Edit: August 26, 2016, 01:34:35 PM by FrugalZony »

Threshkin

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Well the tax consequence already applies as a green card holder, unless she's willing to give up her GC once you move.
But you, as a USC, will still be taxable with your world income in the US no matter where you live.
If both of you live in the US right now, I suppose your wife holds a gc?

Assuming your wife qualifies for US citizenship (check USCIS website for eligibility info https://www.uscis.gov/sites/default/files/files/article/chapter4.pdf)
If your wife wants to be a DUAL citizen, she needs to apply for a "Beibehaltungsgenehmigung" first BEFORE doing anything on the US side.
If she just applies for US citizenship without receiving this BBG, she'll loose the German citizenship.
Here's more reading on that on the official German site:
http://www.germany.info/Vertretung/usa/de/05__Dienstleistungen/02__Staatsangehoerigkeit/02__Beibehaltung/__Beibehaltung.html

There's also tons of resources online, including  Yahoo and FB groups, where people, who have gone through the processes (both BBG and USC) help each other out with tips
and sample documents etc.
Feel free to message me if you you want links, I know several folks who have gone through these recently. I'm sure they'd be happy to give her pointers.

As others have said, the EU is a huge patchwork of countries with very different health systems and other circumstances, so it's hard to give specific advice unless you narrow it down to a couple of countries that you are considering.

Thanks FrugalZ.  This looks very useful.

Yes, my DW has a Green Card and she qualifies per the guidelines.