US Expats in the Philippines: UITFs, SRRV & FTC vs FEIE (2026)
The Philippines is home to one of the world's largest American citizen communities abroad — an estimated 220,000+ registered, with significantly more residing under various visa categories. The draw is real: tropical climate, English widely spoken, low cost of living by Western standards, warm culture, and deep family ties for Filipino-Americans returning home. US military veterans and civilian federal retirees have long made the Philippines a top retirement destination, drawn by the dollar's purchasing power and the SRRV retirement visa's accessibility. Younger US expats work in Metro Manila's BPO industry and multinational corporate offices, or freelance remotely from Cebu or Davao. The US tax planning challenges are specific to this country: no US-Philippines totalization agreement means full SE tax exposure regardless of FEIE election; every Philippine pooled investment product is a PFIC; foreign nationals are constitutionally barred from owning land; and the SRRV deposit structure creates ongoing US reporting obligations from day one. Understanding these issues before moving — not after — is the difference between a well-structured relocation and years of compliance catch-up.
1. Philippine Income Tax for Resident Aliens (TRAIN Law, 2026)
The Philippines taxes resident aliens — non-Filipino citizens who reside in the Philippines — on Philippine-source income only.1 US citizens living in the Philippines as resident aliens are not subject to Philippine income tax on foreign-source income: US Social Security, US pension and IRA distributions, US brokerage dividends, US rental income, and other income from non-Philippine sources is entirely outside the Philippine Bureau of Internal Revenue's reach. This is meaningfully more favorable than high-tax European countries, where residents are taxed on worldwide income.
For Philippine-source employment and business income, the TRAIN Law (Republic Act 10963) Phase 2 schedule — effective January 1, 2023 and unchanged for 2026 — applies:
| Taxable Income (PHP) | Rate | Approx. USD (₱57.50:$1) |
|---|---|---|
| Up to ₱250,000 | 0% | up to ~$4,350 |
| ₱250,001 – ₱400,000 | 15% | $4,350 – $6,960 |
| ₱400,001 – ₱800,000 | 20% | $6,960 – $13,915 |
| ₱800,001 – ₱2,000,000 | 25% | $13,915 – $34,780 |
| ₱2,000,001 – ₱8,000,000 | 30% | $34,780 – $139,130 |
| Over ₱8,000,000 | 35% | above ~$139,130 |
Exchange rate (₱57.50:$1) is illustrative. Philippine-source income for resident aliens includes: salary from a Philippine employer or Philippine operations of a foreign employer, Philippine-sourced business income, Philippine dividends (subject to 10% final withholding), interest on Philippine peso bank deposits (20% final withholding for non-residents), and capital gains on Philippine real estate and unlisted shares. Minimum wage earners are fully exempt from income tax on statutory minimum wages, overtime, holiday pay, and hazard pay.1
2. FEIE vs Foreign Tax Credit: Why FTC Usually Wins for Working Expats
For US citizens earning employment or business income from Philippine sources, the Foreign Tax Credit (FTC) is generally the better strategy — though the analysis is more nuanced than in a high-tax country like Japan or Germany.
How FTC works in the Philippines: Philippine income tax paid at the graduated rates above is creditable against your US federal income tax on the same income. At the income levels where most US expat professionals in the Philippines operate (roughly ₱800K–₱5M, or $14K–$87K), Philippine effective tax rates run 19–26% — matching or exceeding US effective marginal rates at the same income levels and eliminating the residual US federal tax entirely.
Example — US professional earning ₱3M/year (~$52,175) in Manila:
- Philippine income tax: ₱402,500 + 30% × (₱3M − ₱2M) = ₱402,500 + ₱300,000 = ₱702,500 (~$12,215, effective rate ~23.4%)
- US federal income tax on $52,175 (single, standard deduction ~$15,600): taxable ~$36,575 → approximately $4,400 (effective ~8.4%)
- FTC available: $12,215 >> US tax of $4,400 → FTC eliminates all US federal income tax with $7,815 excess FTC carryforward (usable for 10 years on future high-FTC returns)
Why FEIE is rarely better for working Philippines expats:
- IRA / Roth IRA elimination: Under IRC §219(f)(1), IRA and Roth IRA contributions require earned income not excluded by FEIE. FEIE-excluding your Philippine salary eliminates IRA and Roth IRA access for that year — a significant long-term cost that the FTC strategy avoids.
- Five-year revocation lock-in: Once elected, revoking FEIE requires a five-year waiting period before re-election. If you later move to a higher-tax country where FTC would be clearly superior, you may be locked into FEIE for years.
- SE tax trap persists regardless: FEIE provides no relief from self-employment tax under IRC §1402(a)(8). Self-employed US citizens in the Philippines owe full US SE tax even if they have a valid FEIE election in place.
When FEIE may be better: Digital nomads earning entirely from foreign clients (non-Philippine-source income) sometimes use FEIE because no Philippine income tax is owed and therefore no FTC is available to claim. If your Philippine employer is in a special economic zone with a tax-exempt incentive structure that exempts employees from Philippine income tax, FEIE can eliminate US tax with no FTC sacrifice. Model your specific numbers with our FEIE vs FTC calculator.
3. No US-Philippines Totalization Agreement: The SE Tax Trap
The United States maintains totalization agreements with 30 countries to prevent dual Social Security taxation.2 The Philippines is not among them. This has direct consequences for self-employed US citizens in the Philippines and those working outside a US-entity payroll structure.
For self-employed US citizens in the Philippines: Net self-employment income — consulting fees, freelance work, online business revenue, or income from a Philippine sole proprietorship — is subject to full US self-employment tax regardless of FEIE election:
- 12.4% Social Security tax on net SE income up to the 2026 SS wage base ($176,100)3
- 2.9% Medicare tax on all net SE income, no ceiling
- 0.9% Additional Medicare Tax on SE income exceeding $200,000 (single) / $250,000 (MFJ)
- Total SE tax on income up to the SS base: 15.3%
This is assessed separately from income tax under IRC §1401 and is not relieved by the Foreign Earned Income Exclusion. A US citizen consulting in the Philippines earning $80,000 owes approximately $12,240 in US SE tax, on top of Philippine income tax and before any US income tax calculation. Without a totalization agreement, there is no certificate of coverage available to exempt Philippine-based earnings from US Social Security obligations.
Philippine SSS (Social Security System) for employed workers: Philippine SSS employer contributions (10% of monthly salary credit, capped at ₱35,000/month) and employee contributions (5%) fund the Philippine social insurance system. SSS is a mandatory social insurance scheme — analogous to US FICA — that provides retirement, disability, and death benefits. Unlike India's EPF, SSS employer contributions do not create a segregated personal account and are not §402(b) employer contributions to a nonqualified plan. The primary issue with SSS and the absence of a totalization agreement is the possibility of dual social insurance contributions for US citizens working under both a US and Philippine payroll simultaneously.4
4. Philippine UITFs, Mutual Funds, and VULs: All PFICs
Philippine banks and insurers offer a wide range of savings and investment products — UITFs (Unit Investment Trust Funds), mutual funds, and VUL (Variable Unit-Linked) insurance policies. For US citizens, every one of these is a Passive Foreign Investment Company (PFIC) under IRC §1297.
What qualifies as a PFIC: A non-US corporation or pooled vehicle where 75%+ of gross income is passive, or 50%+ of assets produce passive income. Every Philippine UITF offered by BDO, BPI, Metrobank, Security Bank, UnionBank, or other Philippine banks meets this test easily. Philippine mutual funds from Sun Life Philippines, First Metro, Philam Asset Management, FAMI, and others likewise qualify. Without a QEF or mark-to-market election, gains trigger the §1291 excess distribution regime — taxed at 37% ordinary income plus a compounding interest charge from the year you first held the position. Our PFIC tax impact calculator shows how severe this penalty becomes over a multi-year holding period.
VUL (Variable Unit-Linked) insurance — a double trap: VUL policies, sold aggressively by Sun Life Philippines, Pru Life UK Philippines, BPI-AIA, and others, combine life insurance with investment sub-accounts that invest in Philippine-domiciled fund units. For US citizens: (1) the underlying fund units are PFICs; (2) the life insurance wrapper typically does not qualify as a life insurance contract under IRC §7702 because Philippine mortality tables and minimum cash value rules differ from US requirements — meaning the investment component gets no tax-deferral treatment and PFIC rules apply to the sub-account holdings. VULs sold to US citizens in the Philippines are rarely suitable and often generate years of compliance problems.
PSE-listed Philippine stocks (not PFICs): Directly owned shares of individual Philippine Stock Exchange companies (PLDT, SM, Ayala, BDO, Jollibee, Meralco, etc.) held in a brokerage account are not PFICs — PFIC classification applies to pooled vehicles, not operating company shares. However, the Philippines imposes a Stock Transaction Tax (STT) of 0.6% on gross selling price on PSE-traded shares, deducted by your broker at settlement. Note: the STT is a gross receipts tax assessed on sales proceeds — not an income tax — and is therefore generally not creditable as a foreign tax credit under IRC §901 (which requires a tax imposed on income). If you hold PSE stocks directly, factor the non-creditable STT into your basis and return calculations.
What to hold instead: US-domiciled ETFs (VTI, VXUS, BND, VWO) in accounts at Interactive Brokers (available for Philippines residents) or Charles Schwab International. Establish the account before leaving the US — some brokers make non-resident account opening more difficult. See our PFIC rules guide for the full QEF vs mark-to-market vs §1291 comparison.
5. SRRV: The US Retiree's Philippine Retirement Visa
The SRRV (Special Resident Retiree's Visa) is issued by the Philippine Retirement Authority (PRA) and allows qualifying retirees — including US citizens — to reside indefinitely in the Philippines. Many US military veterans, federal retirees, and civilian pensioners use the SRRV as their long-term visa, drawn by the dollar's purchasing power and the Philippines' low cost of living.
SRRV Classic deposit requirements (effective September 1, 2025):5
| Applicant Profile | Required Deposit (USD) |
|---|---|
| Age 50+, with qualifying pension ($800+/mo single; $1,000+/mo couple) | $15,000 |
| Age 50+, without qualifying pension | $30,000 |
| Age 40–49, with qualifying pension | $25,000 |
| Age 40–49, without qualifying pension | $50,000 |
| SRRV Courtesy (ex-military, diplomats, former Filipinos), age 50+ | $1,500 |
The deposit must be remitted from a bank account in your name outside the Philippines into a PRA-accredited Philippine bank special time deposit account. You must obtain a Letter of Introduction (LOI) from the PRA before transferring funds. Additional dependents require a separate deposit per dependent (except for former Filipinos).
US tax treatment of the SRRV deposit:
- The deposit itself is not a taxable event — it is a transfer of existing assets to a foreign bank account, not a disposition or taxable distribution.
- Interest on the deposit is US-taxable. Philippine banks pay time deposit interest (currently ~4–5% annually on USD deposits). The Philippines withholds final tax on interest paid (rate varies by deposit type and residency status — typically 20% on peso time deposit interest for non-residents). This withholding is a creditable foreign tax under IRC §901, creating an FTC opportunity. A $15,000 SRRV deposit earning 4% generates $600/year in US-taxable interest income, with Philippine withholding potentially offsetting the US tax bill.
- SRRV holders are resident aliens for Philippine tax purposes — taxed on Philippine-source income only. A US retiree living on US Social Security, US military retirement pay, or US pension distributions pays Philippine income tax on exactly zero of that income. The Philippine income tax exposure for most SRRV holders is nil.
- FBAR reporting required from day one. The SRRV deposit account at a Philippine bank is a foreign financial account and must be reported on FBAR (FinCEN 114) and counted toward Form 8938 FATCA thresholds. See Section 8.
6. Philippine Real Estate: The Land Ownership Prohibition
The Philippine Constitution (Article XII, Section 7) prohibits foreign nationals — including US citizens — from owning land in the Philippines. This is a constitutional prohibition, not a regulatory limitation. It cannot be worked around through nominee arrangements, corporations with foreign majority ownership, or other structures — using a Filipino nominee to hold land on your behalf is illegal and unenforceable.
What US citizens can own:
- Condominium units under the Condominium Act (Republic Act 4726), provided the total foreign ownership in the project does not exceed 40% of all units. Metro Manila's condo market is substantial; many towers in Bonifacio Global City, Makati CBD, Ortigas, and Cebu Business Park have foreign quota availability.
- Structures on leased land: A US citizen can own a house/building while leasing the underlying land. Long-term land leases (up to 50 years with a single 25-year renewal) are legally recognized but carry title risk upon lease expiry or landowner death.
US tax treatment of Philippine real estate:
- §121 principal residence exclusion: A US citizen who uses a Philippine condo as a principal residence may exclude up to $250,000 ($500,000 MFJ) of gain from US federal income tax, provided the 2-of-5-year ownership and use tests are met. The exclusion applies to the USD-equivalent gain, computed using dollar-denominated cost basis and proceeds.
- Philippine Capital Gains Tax (CGT): The Philippines imposes a 6% final CGT on the higher of gross selling price or fair market value of real property.6 This CGT is creditable under IRC §901 — it is an income-based tax on the gain from disposition — creating FTC to offset US capital gains tax on the same transaction (net of any §121 exclusion already applied).
- Currency gain on PHP-denominated financing: If you finance a Philippine purchase with a peso-denominated mortgage, USD appreciation relative to the peso between loan origination and payoff creates a §988 currency gain taxable as ordinary income in the US. In a stable exchange rate environment this is modest; on a ₱10M loan (~$174K), a 5% peso appreciation creates ~$8,700 of ordinary income.
- Philippine Documentary Stamp Tax (DST): 1.5% of property value on the deed of absolute sale. This is a transaction tax, not an income tax, and is not creditable as FTC.
7. US-Philippines Income Tax Treaty: The Saving Clause
The US and the Philippines have an income tax treaty signed in 1976 and in force since October 16, 1982.7 Like most US income tax treaties, it contains a saving clause preserving the US's right to tax its own citizens as if the treaty had never been signed. This means most treaty protections — reduced withholding rates, tiebreaker provisions, pension deferral — are unavailable to US citizens.
What the saving clause eliminates for US citizens:
- Treaty provisions cannot be used to shelter Philippine-source income from US tax — the US asserts worldwide taxation regardless of any treaty benefit the Philippines might otherwise provide
- Treaty-based reduced dividend and interest withholding rates that might otherwise apply cannot be claimed by US citizens to reduce Philippine withholding on investment income (Philippine domestic withholding rates govern)
What the treaty provides in practice:
- Philippine government pensions: Pensions paid by the Philippine government to former Philippine government employees are typically taxable only in the Philippines under the treaty's government pay article — this provision is often carved out of the saving clause for US citizens, potentially providing protection from US tax on a Philippine government pension in specific circumstances. Verify with a cross-border advisor if this applies to your situation.
- Mutual Agreement Procedure (MAP): If both countries tax the same income without adequate credit relief, MAP provides a resolution mechanism. Rarely used in practice but available as a backstop.
For operational purposes, most US citizens in the Philippines rely on the FTC mechanism rather than treaty provisions. The 1982 treaty's limited scope means US expats should not plan around treaty benefits that the saving clause largely negates.
8. FBAR, FATCA, and the Philippine Model 1 IGA
The Philippines signed a FATCA Intergovernmental Agreement (Model 1 IGA) with the United States, in force since 2014.8 Philippine financial institutions report US account holders to the Bureau of Internal Revenue (BIR), which exchanges information with the IRS. The IRS receives automatic annual data on your Philippine bank accounts, brokerage accounts, and other financial accounts — whether you report them or not.
FBAR (FinCEN 114) — file if aggregate foreign account balance exceeds $10,000 at any point:
- Philippine peso and USD bank accounts at any Philippine bank (BDO, BPI, Metrobank, UnionBank, Security Bank, PNB, etc.)
- SRRV special time deposit account at the PRA-accredited bank — from the day of initial funding
- Philippine brokerage accounts (COL Financial, BDO Securities, BPI Trade) for PSE stock holdings
- Pag-IBIG (HDMF) provident fund account and MP2 (Modified Pag-IBIG II) savings account — conservative practitioners report these; IRS has not issued definitive guidance, but the signature-authority rule applies to accounts with balances above the threshold
Form 8938 (FATCA) thresholds for US citizens abroad: $300,000 (single) / $600,000 (MFJ) at any point, or $200,000 / $400,000 at year-end. SRRV holders with a deposit account, Philippine checking, and any additional savings often exceed the FBAR $10,000 threshold immediately. Form 8938 thresholds are typically crossed by US expats with significant Philippine-held savings.
FATCA bank access: The major Philippine commercial banks (BDO, BPI, Metrobank, UnionBank) maintain FATCA compliance programs and generally open accounts for US citizens with proper documentation (passport, W-9, visa documentation). Smaller community banks may decline US persons due to FATCA compliance costs — factor this into banking decisions before arriving.
9. Philippine Estate Tax and US Estate Planning
The Philippines imposes estate tax at a flat rate of 6% on net estate — applied to Philippines-situated assets of non-resident aliens (which includes US citizens who are Philippine resident aliens but not Philippine citizens).9 Philippine-situated assets include Philippine real estate, Philippine bank deposits, and Philippine stock holdings.
For US federal estate planning, US citizens are subject to US estate tax on worldwide assets. The 2026 federal estate tax exemption is $15,000,000 (increased permanently under the One Big Beautiful Bill Act, July 2025).10 For most US expats in the Philippines, the US exemption far exceeds their estate size, and the Philippine 6% estate tax on Philippine-situated assets is the more immediate concern to plan around.
If you have a Filipino (non-citizen) spouse, the unlimited US marital deduction is unavailable — bequests to non-citizen spouses do not qualify under IRC §2056(d). A Qualified Domestic Trust (QDOT) is required to defer US estate tax on property passing to a non-citizen spouse. Annual lifetime gifts to a non-citizen spouse are capped at $194,000 in 2026 (indexed annually).10 See our non-US spouse planning guide for the full QDOT and annual gift analysis.
10. What to Do Before Moving to the Philippines
- Model FTC vs FEIE for your income structure. If you will have Philippine-source employment income, run the comparison using our FEIE vs FTC calculator. If you are retiring on US pension or Social Security only, confirm your Philippine income tax liability will be near zero — no Philippine-source earned income means no Philippine income tax and no FEIE/FTC decision needed on that income stream.
- Liquidate Philippine UITFs, mutual funds, and VUL positions before departure. If you have Philippine investment accounts from prior visits or family-connected savings, exit these before becoming a PFIC-exposed US taxpayer. Post-arrival purchase of Philippine pooled investment products should not occur. If you already hold UITFs or VULs, work with a cross-border advisor to exit them in the most tax-efficient manner possible.
- Open a US-accessible brokerage account before departing. Interactive Brokers (accounts available for Philippines residents) or Charles Schwab International are standard. Establish the account while you still have a US address — some brokers make non-resident account opening more difficult.
- Sever your US state tax domicile before departing. California and New York are the most aggressive states. Update driver's license, voter registration, and professional registrations before your move date. California does not recognize FEIE and will tax your worldwide income if it still considers you domiciled there. See our state residency guide for the domicile-severance checklist.
- Start the SRRV process early. PRA deposit must be remitted from an overseas bank account. Request the Letter of Introduction from PRA before transferring any funds. Budget 6–8 weeks for the full process. US military veterans and former US government employees should check SRRV Courtesy eligibility — the $1,500 deposit requirement is a fraction of the standard SRRV Classic.
- Track all Philippine bank accounts from Day 1. FBAR's $10,000 aggregate threshold is crossed within the first week of funding the SRRV deposit or a Philippine checking account. Set up a tracking record for each account's high-water mark balance throughout the year.
- Do not hold land through nominees. Filipino nominee arrangements for land ownership are constitutionally void and criminally risky. If you want real estate in the Philippines, use a condo within the 40% foreign quota or a properly documented long-term land lease.
- If self-employed or freelancing remotely: US SE tax (15.3%) applies to all net SE income regardless of residence or FEIE election. Structure any Philippine business entity with cross-border tax advice before signing Philippine client contracts. Model whether a foreign corporation structure (with implications for GILTI, Subpart F, and PFIC rules on the corporate earnings) is better than direct SE income for your specific situation.
- Plan the SRRV deposit interest and FBAR reporting from the first year. Know your bank's withholding rate on deposit interest, retain the annual interest statements, and document the FTC claim. Small amounts, but a real annual reporting obligation starting the first tax year you fund the account.
What a Philippines-Specialist Expat Advisor Handles
A generalist US RIA will often decline to serve non-US-resident clients. A Filipino financial advisor has no training in IRC §1297, Form 8621, FBAR, or US SE tax. A US-licensed, fee-only cross-border specialist who works actively with US citizens in the Philippines handles both sides:
- FTC vs FEIE decision modeling specific to your Philippine income, filing status, and employer structure
- UITF / mutual fund / VUL PFIC divestiture — how to exit positions before departure without triggering unnecessary US gains
- SRRV deposit structuring, ongoing interest reporting, and FTC claim on Philippine deposit withholding
- PSE brokerage FBAR reporting and STT non-creditability analysis for Philippine equity holdings
- Self-employment SE tax planning for consultants and freelancers working remotely from the Philippines
- Philippine real estate structuring: condo within foreign quota, §121 eligibility analysis, 6% CGT FTC modeling, currency gain planning
- US state domicile severance documentation for California, New York, and other aggressive states
- Filipino (non-citizen) spouse planning: QDOT trust structuring, $194,000 annual gift exclusion, FBAR signature authority over joint Philippine accounts, Social Security eligibility for non-citizen spouses
- Philippine 6% estate tax coordination with US estate planning for Philippine-situated assets
- Exit tax analysis under IRC §877A for clients considering renouncing US citizenship after long-term Philippines residency
Get matched with a Philippines-specialist expat advisor
Fee-only advisors who work with US citizens in the Philippines — PFIC, FTC, SRRV, FBAR. 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.
- Bureau of Internal Revenue (BIR), Philippines / TRAIN Law (Republic Act 10963): Graduated income tax rates for resident aliens effective January 1, 2023 (Phase 2). Schedule: 0% up to ₱250,000; 15% on ₱250,001–₱400,000; 20% on ₱400,001–₱800,000; 25% on ₱800,001–₱2,000,000; 30% on ₱2,000,001–₱8,000,000; 35% above ₱8,000,000. Resident aliens taxed on Philippine-source income only per National Internal Revenue Code §23(B). bir.gov.ph
- SSA: International Programs — U.S. International Social Security Agreements. The SSA maintains totalization agreements with 30 countries; the Philippines does not appear on the official SSA country list. No Certificate of Coverage mechanism is available for Philippines-based US workers. ssa.gov/international/agreements_overview.html
- IRS Rev. Proc. 2025-67: Social Security wage base for 2026 is $176,100. Self-employment tax: 12.4% SS + 2.9% Medicare = 15.3% on net SE income up to the SS base; 2.9% Medicare on all net SE income above the base. IRC §1401. irs.gov — topic 554 self-employment tax
- Philippine Social Security System (SSS): Contribution schedule for 2026 — total rate 15% (employer 10%, employee 5%), monthly salary credit maximum ₱35,000. SSS is a mandatory social insurance system under Republic Act 11199 (Social Security Act of 2018), providing retirement, disability, death, sickness, and maternity benefits. sss.gov.ph
- Philippine Retirement Authority (PRA): SRRV Classic and SRRV Courtesy deposit requirements effective September 1, 2025. Classic: $15,000 (age 50+, qualifying pension) / $30,000 (age 50+, no pension) / $25,000 (age 40–49, qualifying pension) / $50,000 (age 40–49, no pension). Courtesy (ex-military, diplomats, former Filipinos): $1,500 age 50+, $3,000 age 40–49 with pension, $6,000 age 40–49 without. Deposit must originate from an overseas account; PRA Letter of Introduction required before transfer. pra.gov.ph — SRRV requirements
- Bureau of Internal Revenue (BIR), Philippines: Capital Gains Tax on real property — 6% final tax on the higher of gross selling price or fair market value per Tax Code §24(D)(1) as amended by TRAIN Law. Generally creditable as a foreign income tax under IRC §901. Philippine Documentary Stamp Tax (1.5%) is a transaction tax and not creditable for FTC purposes. bir.gov.ph — capital gains tax real property
- IRS: United States-Philippines Income Tax Treaty. Convention signed October 1, 1976; in force October 16, 1982. Saving clause preserves US right to tax its citizens as if the treaty had not been signed. Treaty text and technical explanation available on IRS treaty documents page. irs.gov — Philippines tax treaty documents
- IRS / BIR Philippines: Philippines-US FATCA Intergovernmental Agreement (Model 1 IGA), in force 2014. Philippine FFIs report US account holders to BIR; BIR exchanges information with IRS under the IGA. irs.gov — FATCA IGA list
- BIR Philippines: Estate tax — 6% flat rate on net estate under TRAIN Law (RA 10963), effective January 1, 2018. Replaces graduated rates up to 20%. Applies to Philippine-situated assets of non-resident aliens. Tax Code §84 as amended. bir.gov.ph — estate tax
- IRC §2523(i): Annual exclusion for gifts to non-citizen spouses. 2026 limit $194,000 per IRS Rev. Proc. 2025-67. Federal estate and gift tax exemption $15,000,000 per OBBBA (One Big Beautiful Bill Act, July 2025), permanently increased. IRC §2010(c). Non-citizen spouses do not qualify for the unlimited marital deduction under IRC §2056(d); a QDOT trust is required for estate tax deferral. See also non-US spouse planning guide.
US tax values verified as of May 2026 against IRS.gov, SSA.gov, and IRS Rev. Proc. 2025-67. Philippine tax values verified against Bureau of Internal Revenue Philippines (bir.gov.ph) and TRAIN Law (RA 10963, Phase 2 schedule effective January 1, 2023). PHP/USD exchange rate references are illustrative (₱57.50:$1); actual values depend on rates at time of transaction. Philippine income tax housing exclusion cap per IRS Notice 2026-25 — confirm the applicable Philippines/Manila location limit at irs.gov. Consult a qualified cross-border advisor for guidance specific to your situation.