US Expats in Costa Rica: Pensionado Visa, Territorial Tax & US Tax Planning Guide (2026)
More than 130,000 US citizens call Costa Rica home — drawn by the Pensionado visa, Central America's highest quality healthcare, the no-income-tax promise of the territorial system, and a lifestyle that's hard to replicate in North America. What's easy to miss: Costa Rica's territorial system eliminates your Costa Rican tax bill on foreign income, but the IRS still taxes US citizens on worldwide income regardless of where they live. Understanding how FEIE interacts with the territorial system, navigating mandatory CCSS (Caja) enrollment, and structuring Costa Rican real estate correctly are the three areas where a specialist's guidance pays for itself.
1. Costa Rica's Territorial Tax System: What It Means for Your US Return
Costa Rica's income tax (Impuesto sobre la Renta) applies only to income earned within Costa Rica — a source-based or territorial system enshrined in the Código de Normas y Procedimientos Tributarios.1 Income from services performed outside Costa Rica, foreign investments, US pensions, US dividends, US capital gains, and US Social Security is entirely outside the Costa Rican taxing authority's reach.
For a US citizen in Costa Rica, the practical breakdown looks like this:
| Income type | Costa Rica taxes it? | US taxes it? | US offset available? |
|---|---|---|---|
| Remote work / freelance performed in Costa Rica for non-CR employer | No | Yes | FEIE up to $132,900 |
| Employment by a Costa Rican company (CR-source wages) | Yes (0–25%) | Yes | FEIE or FTC (CR income tax creditable) |
| US Social Security | No | Yes (up to 85%) | None — not "earned income" |
| US pension / IRA / 401(k) distributions | No | Yes (ordinary income) | None — not "earned income" |
| US dividends, interest, capital gains | No | Yes (normal US rates) | None |
| Costa Rican rental income (local property) | Yes (15% withholding on gross or net) | Yes | FTC on CR income tax paid |
The retiree trap. US retirees who move to Costa Rica on Social Security, pension income, and US investment portfolios enjoy zero Costa Rican income tax on those amounts. But they pay full US income tax on all of it — with no foreign tax credit to offset, because Costa Rica isn't taxing anything they have. Costa Rica's territorial system saves nothing on their 1040. The primary US tax benefit of living in Costa Rica applies to working expats who use FEIE. Retirees benefit from the cost of living, healthcare, and Pensionado discounts — not from any reduction in their US income tax bill.
Costa Rica income tax rates (2026, for CR-source income only):1
| Taxable income (CRC) | Approximate USD | Rate |
|---|---|---|
| Up to ₡6,244,000 | ~$12,700 | 0% |
| ₡6,244,001 – ₡8,329,000 | ~$12,700 – $17,000 | 10% |
| ₡8,329,001 – ₡10,414,000 | ~$17,000 – $21,200 | 15% |
| ₡10,414,001 – ₡20,828,000 | ~$21,200 – $42,400 | 20% |
| Above ₡20,828,000 | Above ~$42,400 | 25% |
For the rare US citizen employed by a Costa Rican company and paying CR income tax, FTC is creditable (CR income tax is an income tax within the meaning of IRC §901). But most US citizens in Costa Rica work remotely for non-CR entities — those earnings are not subject to any CR income tax, making FEIE the only available offset.
2. FEIE vs Foreign Tax Credit: FEIE Wins for Most Costa Rica Expats
US citizens use one of two primary mechanisms to avoid double taxation on foreign earned income:
- Foreign Earned Income Exclusion (FEIE, Form 2555) — excludes up to $132,900 of foreign earned income from US gross income in 2026.2
- Foreign Tax Credit (FTC, Form 1116) — credits income taxes paid to a foreign country against US tax liability, dollar for dollar.3
For most US citizens in Costa Rica, FEIE is the correct strategy for earned income. The reason is simple: Costa Rica doesn't tax foreign-earned income from remote work or services performed for non-CR employers. There is no Costa Rican income tax to credit via Form 1116. FTC requires a qualifying foreign income tax — with zero CR tax on your remote work earnings, FTC produces $0 in credits. FEIE, which requires no underlying foreign tax, is the only tool available.
FEIE eligibility requires:
- 330-day physical presence test — physically present outside the US for at least 330 full days in any consecutive 12-month period. Use our FEIE physical presence calculator to verify your count.
- Or bona fide residence test — established bona fide resident of Costa Rica (or any foreign country) with intent to remain indefinitely. A Costa Rican Pensionado, Rentista, or Digital Nomad visa typically establishes bona fide residency.
Important FEIE limitations:
- FEIE excludes only earned income (wages, self-employment income from services). US Social Security, pension distributions, IRA withdrawals, dividends, and capital gains are not "earned income" and are never excluded.
- Self-employment tax applies in full even on FEIE-excluded income — see Section 3 below.
- Excluding income under FEIE removes it from IRA contribution calculations — if you fully exclude all earned income, you lose IRA/Roth IRA contribution eligibility for that year. See our IRA contribution calculator for expats.
- The five-year revocation lock-in: revoking a FEIE election bars re-election for five years. Don't elect carelessly.
Use our FEIE vs FTC calculator to model both strategies against your income. The one scenario where FTC helps in Costa Rica: if you are employed by a Costa Rican company earning CR-source wages and paying CR income tax at 10–25%, FTC is creditable on that income. But the applicable rates are lower than US rates — FEIE may still produce a better outcome below $132,900. Remote workers, Digital Nomad visa holders, and retirees have no CR income tax to credit and should use FEIE exclusively for earned income.
3. Self-Employment Tax Trap: No US-Costa Rica Totalization Agreement
This is the most expensive surprise for self-employed US citizens in Costa Rica. IRC §1402(a)(8) explicitly states that the FEIE does not reduce net earnings from self-employment for self-employment tax purposes. Even if you exclude $132,900 of freelance income under FEIE, you still owe:4
- 15.3% self-employment tax on the first $184,500 of net SE earnings (2026 Social Security wage base: $184,500; combined rate = 12.4% SS + 2.9% Medicare)
- 2.9% Medicare tax on net SE earnings above $184,500
- 0.9% Additional Medicare Tax on net SE earnings above $200,000 ($250,000 MFJ)
There is no US-Costa Rica totalization agreement.5 In countries with totalization agreements (UK, Germany, Canada, Australia, France), a Certificate of Coverage from one country's social security agency certifies you to pay into only one system. Costa Rica is not in that group. A freelancer in Costa Rica netting $100,000 owes approximately $14,130 in SE tax even after FEIE eliminates their income tax entirely.
Compounding the issue: legal Costa Rican residents must also enroll in CCSS (Caja) as "trabajadores independientes" (see Section 5). CCSS contributions are not creditable as foreign income taxes and don't count toward your US Social Security record. The self-employed US citizen in Costa Rica faces a double social insurance burden with no coordination mechanism between the two systems.
Entity structure options for the self-employed:
- S-corporation (US entity): An S-corp paying you a reasonable salary and distributing the rest as dividends can reduce SE-taxable wages. Compliance cost is significant (payroll, 941s, state filings) and the IRS scrutinizes unreasonably low salaries. Worthwhile at $150K+ net SE income — model it with a cross-border advisor first.
- Partial FEIE with Solo 401(k): If you don't exclude all earned income under FEIE, you preserve earned income for IRA/Solo 401(k) contributions ($72,000 employer + employee maximum in 2026, plus $8,000 catch-up at age 50+ and $11,250 super-catch-up at ages 60–63). Leaving $30K–$50K on your return, taxed at 10–12%, can cost less over a career than losing years of tax-advantaged compounding.
4. Visa Options and US Tax Implications
Costa Rica offers three residency paths commonly used by US citizens. Each has distinct income requirements — and different implications for your US filing strategy.
Pensionado Visa
Costa Rica's Pensionado visa requires a minimum of $1,000/month of guaranteed lifetime income from a pension, Social Security, annuity, or similar permanent income source.6 Income cannot be fixed-term or discretionary. Additional dependents require $500/month each. The visa grants temporary residency (renewable) that converts to permanent residency after three years.
Pensionado benefits (Ley 7293 and updates):
| Category | Discount |
|---|---|
| Utilities (electricity, water, telephone) | 20% |
| Prescription medications | 15% |
| Hospitalization, medical consultations, diagnostic tests | 10–15% |
| Restaurants | 15% |
| Air travel (domestic) | 30% |
| Entertainment (cinemas, theaters, spectator sports) | 50% |
US tax implications for Pensionado holders. The Pensionado visa changes nothing about US tax obligations. US Social Security received in Costa Rica is taxable on your 1040 by the same combined-income formula (up to 85% included in taxable income). Pension distributions are ordinary income. Because Costa Rica doesn't tax any of this income, there is no FTC to offset your US liability. A US retiree in Costa Rica on $60,000/year of Social Security and pension income pays essentially the same federal income tax as they would from Texas — the difference is the Costa Rican bill doesn't exist.
Rentista Visa
The Rentista visa is for financially independent individuals who have passive income of at least $2,500/month from sources outside Costa Rica — such as US investment portfolio distributions, rental income, or trust distributions — for at least the next 24 months, proven by a letter from a US bank or investment institution.6 Same three-year path to permanent residency as Pensionado.
Rentista income is predominantly passive — US dividends, interest, and portfolio withdrawals. None of it is "foreign earned income" for FEIE purposes, and Costa Rica doesn't tax it. The Rentista is in the same tax position as the Pensionado: full US income tax, zero CR income tax, zero FTC offset.
Digital Nomad Visa (Law 9996)
Costa Rica's Digital Nomad visa (enacted 2021, Law 9996) permits remote workers earning income exclusively from outside Costa Rica to live there for up to one year, renewable once (two years total).7 Requirements:
- Minimum income: $3,000/month for individuals; $4,000/month for families
- Income must come from sources outside Costa Rica (remote employment, freelance, online business)
- Health insurance with minimum $50,000 coverage
- Application fee: $100
- Renewal requires minimum 80 days of physical presence in Costa Rica during the first year
The law explicitly exempts Digital Nomad holders from Costa Rican income tax on their foreign-sourced income — which merely codifies what the territorial system already implies. For US citizens, this means FEIE is the only tool: exclude up to $132,900 of foreign earned income from your US gross income once you meet the 330-day test or establish bona fide residency. There is no CR FTC to use. The Digital Nomad visa does not exempt you from CCSS enrollment obligations — check current Caja guidance, as enforcement for Digital Nomad holders has evolved since 2021.
5. CCSS (Caja) Enrollment: Mandatory, Not Creditable, and Not Coordinated
The Caja Costarricense de Seguro Social (CCSS) provides Costa Rica's universal healthcare and pension system. Legal residents — including Pensionado, Rentista, and permanent residency holders — are required to enroll and contribute. 2026 contribution rates (adjusted effective January 1, 2026):8
- Employees of CR companies: 10.83% employee + 26.83% employer of gross wages
- Independent workers and self-employed residents: Contributions based on a declared income base (set at or above the minimum established by Caja; rates parallel the employee structure)
- Pensionados and Rentistas: Voluntary enrollment or enrollment based on a minimum income declaration; the Caja minimum monthly payment varies by Caja category
The non-creditability problem. CCSS contributions are social insurance contributions, not income taxes. The IRS has clarified that certain Costa Rican taxes and social contributions do not qualify as creditable under IRC §901.9 CCSS contributions cannot be claimed on Form 1116. You pay them to access Costa Rica's healthcare system — a benefit in kind — but they reduce neither your US income tax nor your SE tax liability.
No totalization coordination. Because there is no US-Costa Rica bilateral Social Security agreement, contributions to CCSS do not reduce your US SE tax, do not generate credits toward US Social Security retirement benefits, and cannot substitute for Medicare contributions. Self-employed US citizens in Costa Rica pay full 15.3% US SE tax and CCSS contributions simultaneously, with no mechanism to eliminate the overlap. Employees of US companies seconded to Costa Rica remain in the US system and owe full FICA — verify with your employer whether a Certificate of Coverage applies in any particular situation.
6. Costa Rica Real Estate: §121, 15% CGT, and CRC Currency Gain
Foreigners can own property directly
Costa Rica grants foreigners the same property ownership rights as citizens — freehold (fee simple) title directly in your name with no fideicomiso trust or special structure required.10 This is a key distinction from Mexico (coastal restriction zone) and some Southeast Asian countries. Property registered in the National Registry under your name is fully owned. The Registro Nacional de la Propiedad is publicly searchable, and title insurance from a Costa Rican title company is available and recommended.
§121 principal residence exclusion
IRC §121 has no geographic restriction — it applies to any primary residence anywhere in the world. If you sell a Costa Rican home that was your primary residence for at least 2 of the last 5 years before the sale, you can exclude up to $250,000 ($500,000 MFJ) of capital gain from US income tax.11
Costa Rica capital gains tax (15%)
Costa Rica charges a 15% flat capital gains tax on real estate and investment gains.12 At closing, a 2.5% advance withholding is applied on the gross sale price (credited against the final 15% tax). The primary residence is exempt. For assets acquired before July 1, 2019 (when the CGT regime was introduced), taxpayers may elect the optional 2.25% simplified rate. The 15% CR CGT is an income-equivalent tax and is creditable via Form 1116 (passive income basket) against your US tax on any gain above the §121 exclusion.
CRC currency gain — the §988 trap
Unlike Panama (USD) and Saudi Arabia (USD-pegged), Costa Rica uses the colón (CRC), which fluctuates against the dollar. Under IRC §988, when you repay a CRC-denominated mortgage, any gain from currency appreciation is treated as ordinary income — not capital gain.13 Example: you borrow ₡100 million for a home at ₡500/USD (cost $200,000), and when you sell five years later the exchange rate is ₡550/USD. The same ₡100 million loan repayment now costs only $181,818 USD — a $18,182 currency gain that is ordinary income on your US return, fully outside §121, and not offset by any Costa Rican tax. US-currency mortgages (through US lenders or some local banks with USD products) eliminate this exposure entirely.
Rental property depreciation
If you rent out Costa Rican property, US tax applies to all net rental income. Foreign residential rental property is depreciated over 30 years under the Alternative Depreciation System (ADS) — not the 27.5-year MACRS that applies to US residential property, per IRC §168(g) as modified by TCJA 2017.14 The Costa Rican tax on rental income (typically withheld at 15% on gross receipts) is creditable via Form 1116 against your US tax on the same rental income.
Transfer tax and property tax
Real estate transfer tax in Costa Rica is 1.5% of the registered value, paid at closing. Annual property tax (Impuesto sobre Bienes Inmuebles) is approximately 0.25% of the registered value — notably lower than US rates. Neither is creditable as a foreign income tax.
7. FBAR, FATCA, and Costa Rican Banking
Costa Rica signed a FATCA Model 1A Intergovernmental Agreement with the United States on November 26, 2013.15 Under this agreement, Costa Rican financial institutions report US account holders' information to Costa Rica's Ministerio de Hacienda, which shares it with the IRS. The era of non-reporting Latin American banking is over for US citizens with Costa Rican accounts.
What you must report as a US citizen in Costa Rica:
- FBAR (FinCEN 114): Required if your aggregate balance in all foreign accounts exceeds $10,000 at any point during the calendar year. Covers: Costa Rican bank accounts, brokerage accounts, and investment accounts. Deadline: April 15 with automatic extension to October 15. Non-willful failure penalty: $16,536 per report per year (2026 inflation-adjusted); willful failure: $165,353 or 50% of account balance, whichever is greater.
- Form 8938 (FATCA): For US persons living abroad, required if total foreign financial assets exceed $300,000 single / $600,000 MFJ at any point during the year (or $200,000/$400,000 on the last day of the year).
Costa Rican banking practicalities. Major Costa Rican banks (Banco Nacional, Banco de Costa Rica, BAC Credomatic) are post-FATCA FFCA compliant and require US citizens to complete W-8/W-9 equivalents, provide source of funds explanations, and sign FATCA consent forms. Opening a basic savings or checking account is generally feasible with a cédula de residencia (residency card), passport, and proof of income. Expats on tourist visas report more difficulty; establishing legal residency first simplifies the process significantly.
8. PFIC Warning: Costa Rican Investment Funds
Any Costa Rican mutual fund, investment fund (fondos de inversión), or unit trust held by a US citizen is a Passive Foreign Investment Company (PFIC) under IRC §1291.16 The §1291 default regime applies punitive interest charges on gains and excess distributions. Do not open Costa Rican investment fund accounts. Maintain your investment portfolio in US-domiciled ETFs and mutual funds through a US custodian. US brokers (Interactive Brokers, Schwab Global Account, TD Ameritrade International) serve US citizens resident abroad — open the account before you move while you still have a US address.
See our PFIC rules guide for the full analysis, including the QEF and mark-to-market elections for funds you already hold.
9. State Taxes: US Domicile Doesn't End at the Tarmac
Moving to Costa Rica doesn't automatically terminate your US state tax liability. If you previously lived in California, New York, or another domicile-aggressive state, that state may continue to assert taxing jurisdiction until you establish a new domicile and sever prior state ties — changing your driver's license, voter registration, professional registrations, and banking relationships. California does not recognize the federal FEIE, meaning if California still considers you a resident, it taxes your worldwide income including income excluded on your federal return. See our state tax residency and domicile guide for what to do before your move.
10. Pre-Move Planning Checklist for Costa Rica
- Confirm your visa path and income thresholds. Pensionado ($1,000/mo permanent pension), Rentista ($2,500/mo passive income with 24-month proof), or Digital Nomad ($3,000/mo from non-CR source). Each requires different documentation — start gathering income verification letters 3–6 months before application.
- Verify your FEIE strategy and 330-day count. If you have earned income, confirm you'll qualify for FEIE via the 330-day test or bona fide residency. Use our FEIE physical presence calculator to track your days.
- Sever your high-tax-state domicile before you leave. Change driver's license, voter registration, and professional licenses. Establish a no-tax domicile (Florida, Texas, Nevada) before departing if you haven't already. See our state residency planning guide.
- Audit your US brokerage accounts. Vanguard, Fidelity, and Schwab may restrict non-resident accounts. Before moving, confirm your custodian's policy or open an account with a custodian known to serve US citizens abroad (Interactive Brokers, Schwab Global Account) while you still have a US address.
- Sell PFIC-exposed investments before you move. If you plan to open a Costa Rican brokerage or investment account, any Costa Rican fondos de inversión are PFICs. Keep your investment portfolio in US-domiciled ETFs. See our PFIC guide.
- Plan the Roth conversion window. Once in Costa Rica with foreign earned income excluded under FEIE, US taxable income may drop dramatically, creating cheap bracket room to convert traditional IRA assets to Roth at 10–12% effective rates. This window closes when you return to the US. See our Roth conversion calculator for expats.
- Consider a USD-denominated mortgage. If you'll purchase real estate with a CRC-denominated loan, model the §988 currency gain exposure. Some local banks and US lenders offer USD mortgages for Costa Rican property — eliminating §988 entirely. The higher interest rate may be worth the tax simplicity.
- Evaluate entity structure for self-employment. If you'll freelance or run a business in Costa Rica, model whether an S-corp or partial FEIE + Solo 401(k) structure reduces the SE tax cost versus FEIE-everything. At $100K+ net SE income, the math often favors a hybrid approach.
- Set your FBAR and CCSS calendar. Open Costa Rican bank accounts, record opening balances, and note the April 15 FBAR deadline (auto-extended to October 15). Also confirm with Caja the enrollment timing and minimum contribution amount for your residency category.
- Healthcare planning. Medicare does not cover services outside the US. Costa Rica's CCSS provides healthcare access for enrolled residents, and private hospitals (CIMA, Clínica Bíblica) are excellent and affordable by US standards. If you'll eventually return to the US and enroll in Medicare, the Part B late enrollment penalty (10%/year, permanent) accumulates during years abroad without qualifying coverage. See our Medicare for expats guide for the IEP, SEP, and IRMAA interaction.
What a Costa Rica–Specialist Expat Advisor Handles
Most US financial advisors decline non-US-resident clients or have no experience with territorial tax systems and CCSS. Most Costa Rican financial advisors have no US tax training. A US-licensed, fee-only advisor who works with US citizens in Costa Rica and Latin America handles:
- FEIE election and 330-day physical presence or bona fide residency documentation
- SE tax reduction strategies (S-corp structure, partial FEIE + Solo 401(k)/SEP-IRA)
- §121 + Costa Rica 15% CGT coordination on real estate sales
- CRC §988 currency gain planning on mortgage debt and bank balances
- Rental property ADS depreciation and FTC coordination (Form 1116, passive basket)
- CCSS enrollment and non-creditability analysis (CCSS vs IRA contribution tradeoffs)
- FBAR/Form 8938 setup and annual compliance for CR bank and brokerage accounts
- State domicile severance documentation
- Roth conversion window modeling during early FEIE years
- Non-US spouse planning: QDOT trust mechanics, non-citizen gift limit ($194,000 in 2026)17
- US brokerage account preservation strategy (which custodians accept non-US-resident US citizens)
- Estate planning under OBBBA's permanent $15M exemption and Costa Rica's civil-law inheritance rules
Get matched with a Costa Rica–specialist expat advisor
Fee-only advisors who understand territorial tax systems, FEIE, CCSS, and US expat obligations in Latin America — not generalists. Free match.
Expat Advisor Match is a matching service. We connect you with vetted fee-only financial advisors in our network — we don't manage money or provide advice ourselves. Advisors in our network are fiduciaries who charge transparent fees (not product commissions), and we match you based on your specific situation.
- Costa Rica Código de Normas y Procedimientos Tributarios and Ley del Impuesto sobre la Renta (Law 7092): territorial source principle — only Costa Rican-source income is taxable. 2026 individual income tax brackets per Ministerio de Hacienda / BDO Costa Rica: 0% (up to ₡6,244,000), 10%, 15%, 20%, 25% (above ₡20,828,000). Brackets updated annually by Hacienda decree. PwC Costa Rica Tax Summaries 2026; BDO Costa Rica — New income tax brackets for 2026.
- IRS Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad — Foreign Earned Income Exclusion. 2026 FEIE limit $132,900 per IRS Rev. Proc. 2025-67. irs.gov/publications/p54
- IRC §901–§905; IRS Form 1116 Instructions (2026). Foreign Tax Credit framework for income taxes paid to foreign governments. irs.gov/forms-pubs/about-form-1116
- IRC §1402(a)(8): self-employment income is not reduced by the FEIE for purposes of computing SE tax. 2026 SS wage base $184,500 per IRS Rev. Proc. 2025-67. irs.gov — Self-Employment Tax
- SSA: Totalization Agreements. Costa Rica is not among the countries with an active US Social Security totalization agreement. ssa.gov/international/agreements_overview.html
- Costa Rica General Directorate of Immigration (DGME): Pensionado visa requires $1,000/month permanent lifetime income; Rentista visa requires $2,500/month passive income provable for 24 months. Confirmed via DGME official requirements (2026). migracion.go.cr
- Costa Rica Law 9996 (Digital Nomad and Remote Worker Act), enacted July 2021. Requirements: $3,000/month individual / $4,000/month family from non-Costa Rican sources; health insurance $50,000+; explicit CR income tax exemption on foreign-source earnings for visa holders. visitcostarica.com — Digital Nomads Requirements
- Costa Rica CCSS (Caja Costarricense de Seguro Social) contribution rates effective January 1, 2026: employee 10.83% (IVM 4.33% + SEM 5.50% + Banco Popular 1.00%); employer 26.83%. Rates adjusted per scheduled IVM pension reform. BDO Costa Rica — CCSS Adjustment Effective January 2026. bdo.cr — CCSS contribution adjustment 2026
- IRS guidance on creditability of foreign taxes under IRC §901: social insurance / payroll taxes generally do not qualify as creditable income taxes. See also Tax Notes: IRS Revenue Ruling clarifying Costa Rican tax creditability. Confirmed via IRS Foreign Tax Credit overview and PwC CR Tax Summaries. irs.gov — Foreign Tax Credit
- Costa Rica Constitution Art. 19: foreigners have the same individual rights as Costa Rican nationals. National Registry (Registro Nacional de la Propiedad): real property registered in personal name of foreign nationals. No special trust or vehicle required for foreigners to own CR real estate outside restricted zones. Costa Rica has no coastal restricted zone equivalent to Mexico's Art. 27.
- IRC §121: Exclusion of gain from sale of principal residence. No geographic limitation on "principal residence." $250,000 single / $500,000 MFJ exclusion; 2-of-5-year ownership and use requirement. irs.gov/publications/p523
- Costa Rica capital gains tax: 15% flat rate on gains from real estate, shares, and other assets introduced July 1, 2019 (LCRI reform). Primary residence exempt. 2.5% advance withholding on gross sale price applied at closing, credited against final 15% liability. Optional 2.25% rate for assets acquired before July 1, 2019 when acquisition and transfer values are independently determined. PwC Costa Rica Tax Summaries 2026. taxsummaries.pwc.com/costa-rica/individual
- IRC §988: gains and losses on foreign currency transactions treated as ordinary income/loss. Currency gain on repayment of CRC-denominated mortgage: difference between USD equivalent of CRC debt at time of incurring vs. repayment is §988 ordinary income or loss. Personal-use exception under §988(e) applies to some personal transactions but the parameters require analysis for mortgage scenarios. IRS Publication 54 and IRC §988(a)(1).
- IRC §168(g)(1)(A): Alternative Depreciation System required for property held for use predominantly outside the US. 30-year ADS recovery period for foreign residential rental property per IRC §168(g)(2)(C)(iv). Post-TCJA effective for property placed in service after December 31, 2017. irs.gov/publications/p527
- FATCA Intergovernmental Agreement between the Government of the Republic of Costa Rica and the Government of the United States of America, Model 1A IGA signed November 26, 2013. US Treasury FATCA IGA list. treasury.gov — FATCA-Agreement-Costa-Rica-11-26-2013.pdf
- IRC §1291 (§1291–§1298): PFIC rules. Foreign mutual funds, investment funds, and unit trusts generally qualify as PFICs. §1291 default regime applies punitive interest on excess distributions. US-domiciled ETFs (registered under Investment Company Act of 1940) are not PFICs. See PFIC rules guide; IRS Form 8621.
- IRC §2523(i): Annual gift tax exclusion for transfers to non-citizen spouses. 2026 limit $194,000 per IRS Rev. Proc. 2025-67. Non-citizen spouses do not qualify for the unlimited marital deduction under IRC §2056(d). See also non-US spouse planning guide and expat estate planning guide.
Tax values verified as of June 2026. US values reflect tax year 2026 law including OBBBA (July 2025) and Social Security Fairness Act (January 2025). Costa Rica values reflect 2026 Ministerio de Hacienda guidelines and CCSS rates effective January 1, 2026.