US Expats in Vietnam: Complete Financial Planning Guide (2026)
Vietnam's expatriate population spans the full spectrum: English teachers and NGO workers in Hanoi, tech professionals and entrepreneurs in Ho Chi Minh City, retirees drawn by low costs and warm climate, and a fast-growing digital nomad community in Da Nang. Whatever brings you there, the US tax picture is more complex than most expect. Vietnam overhauled its personal income tax system in 2026, cutting from seven brackets to five while raising the top bracket threshold. A US-Vietnam income tax treaty was signed in 2015 but has never been ratified — leaving US citizens without treaty-based protections that expats in Europe or Australia take for granted. There is no US-Vietnam totalization agreement, meaning self-employed US citizens pay full US self-employment tax on top of Vietnamese social insurance. Vietnamese investment funds are PFICs. And Vietnamese social insurance contributions — mandatory for foreigners on 12-month-plus contracts — are not creditable against US taxes. The specialist intersection of US tax compliance and Vietnamese financial planning is narrow.
1. Vietnam Personal Income Tax: The New 2026 Five-Bracket System
Vietnam enacted a comprehensive Personal Income Tax (PIT) reform in late 2025, effective January 1, 2026, reducing the progressive tax schedule from seven brackets to five while raising thresholds for middle and upper bands. The key change for expats: the top bracket threshold rises from VND 80 million to VND 100 million per month.1
Vietnam 2026 PIT Brackets (Employment Income — Tax Residents)
| Taxable Monthly Income (VND) | Annual Equivalent | Approx. USD/yr (at 25,000 VND/$) | Rate |
|---|---|---|---|
| 0 – 10,000,000 | 0 – 120M VND | 0 – $4,800 | 5% |
| 10,000,001 – 30,000,000 | 120M – 360M VND | $4,800 – $14,400 | 10% |
| 30,000,001 – 60,000,000 | 360M – 720M VND | $14,400 – $28,800 | 20% |
| 60,000,001 – 100,000,000 | 720M – 1.2B VND | $28,800 – $48,000 | 30% |
| Over 100,000,000 | Over 1.2B VND | Over $48,000 | 35% |
Exchange rate of 25,000 VND/USD is illustrative. Taxable income is gross income minus the personal deduction (VND 15,500,000/month = ~$7,440/year) and dependent deductions (VND 6,200,000/month per dependent = ~$2,976/year). Tax residents: defined as present in Vietnam 183+ days in a calendar year, or holding a registered permanent residence card or rented accommodation registered for 183+ days. Non-residents: flat 20% on Vietnam-sourced income only.
For context: a US professional earning VND 60,000,000/month gross (~$28,800/year) with no dependents has taxable income of approximately VND 44,500,000/month (after VND 15.5M personal deduction) — falling in the 20% bracket with an effective rate around 13%. At VND 100,000,000/month (~$48,000/year), effective Vietnamese PIT is roughly 23–25% after deductions. These are modest rates compared to Germany, France, or Japan — which is why the FEIE is usually the right call for US citizens in Vietnam.
2. FEIE vs Foreign Tax Credit: FEIE Usually Wins in Vietnam
US citizens abroad have two primary tools to reduce double taxation on foreign employment income:
- Foreign Earned Income Exclusion (FEIE, Form 2555) — excludes up to $132,900 of foreign earned income from US gross income in 2026.2 Must qualify via the bona fide residence test or 330-day physical presence test.
- Foreign Tax Credit (FTC, Form 1116) — applies Vietnamese PIT actually paid against your US tax liability, dollar-for-dollar, up to the FTC limitation (the US tax allocable to foreign-source income).
For most US citizens working in Vietnam in 2026, the FEIE produces better results:
Example: FEIE vs FTC for a US professional in Ho Chi Minh City
US citizen, single, employed by a Vietnamese subsidiary, earning VND 800,000,000/year (~$32,000/year), no dependents:
- Taxable Vietnamese income: ~VND 614,000,000/year (after VND 186M personal deduction)
- Vietnamese PIT on taxable income: approximately VND 95,800,000 (~$3,832; effective rate ~12% of gross)
- US federal tax on $32,000 gross (single filer, 2026 standard deduction $16,100): approximately $2,375
- With FEIE: Full $32,000 excluded (well within $132,900 cap) → zero US federal income tax. Vietnamese PIT paid is irrelevant to US calculation.
- With FTC: $3,832 Vietnamese PIT credit fully offsets $2,375 US liability → also zero, with ~$1,457 FTC carryforward to use in future years. Similar outcome here, but more complex and creates a passive basket limitation issue if you have investment income.
FEIE wins for most Vietnam-based earners for the same reason it wins in other medium-tax countries: Vietnamese effective rates are below US marginal rates, so FEIE eliminates US tax without requiring you to pay Vietnamese tax first. FEIE also has no income basket complexity — unlike FTC's passive/general/foreign branch basket system.
However, FEIE has three important costs to weigh:
- IRA/Roth IRA eligibility: FEIE-excluded earned income does not count as compensation for IRA purposes (IRC §219(f)(1)). If you exclude all earned income, you cannot contribute to an IRA or Roth IRA for that year. The partial FEIE strategy — excluding only enough to reduce your US tax to zero — can preserve $7,500/year ($8,600 if age 50+) of IRA contribution access at low marginal cost. See our IRA contribution calculator for expats.
- Passive income: FEIE covers only earned income (wages, self-employment income). Interest, dividends, capital gains, and rental income are not excludable — FTC is the only tool for those income types.
- Five-year revocation lock-in: Once you revoke the FEIE election, you cannot re-elect for five years without IRS consent. Changing countries or employment structures mid-career can trap you.
Use our FEIE vs FTC calculator to model your specific income, filing status, and Vietnamese effective rate.
3. No Ratified US-Vietnam Income Tax Treaty
A comprehensive income and capital gains tax treaty between the United States and Vietnam was signed in 2015, but as of 2026 it has not been ratified by the US Senate and is not in force.3
The practical consequences for US citizens in Vietnam are significant:
- No saving clause to complain about. The saving clause (present in nearly every US tax treaty) generally prevents US citizens from using treaty benefits against the US. With no treaty, there is no saving clause — but also no tiebreaker article, no treaty-based pension deferral, and no reduced withholding rates.
- No treaty-based pension deferral. Countries with treaties that include pension articles (UK, Germany, France) can often defer US tax on employer pension contributions until distribution. Vietnam has no such arrangement — any Vietnamese employer retirement or savings plan must be analyzed under domestic US law, typically §402(b) (employer contributions are taxable US income in the year vested) or PFIC rules.
- Tiebreaker unavailable. US citizens who simultaneously qualify as Vietnamese tax residents (183+ days) and would otherwise be US residents can't use an Article 4 tiebreaker to elect Vietnamese-only residency — because there is no tiebreaker article. US worldwide taxation applies in full.
- No withholding rate reduction. Vietnamese withholding on dividends, royalties, and services paid to US entities runs at standard Vietnamese rates rather than a treaty-reduced rate.
4. Vietnamese Social Insurance: The §402(b) Trap
Foreign nationals working in Vietnam on work permits with labor contracts of 12 months or more are required to participate in Vietnam's mandatory social insurance system since 2018.4 The 2026 contribution rates for foreigners:
| Fund | Employer Rate | Employee Rate |
|---|---|---|
| Social Insurance (BHXH) | 17.5% | 8.0% |
| Health Insurance (BHYT) | 3.0% | 1.5% |
| Unemployment Insurance (BHTN) | N/A (exempt) | N/A (exempt) |
| Total | 20.5% | 9.5% |
Contribution base is capped at VND 46,800,000/month (~$1,872) in 2026. Foreign employees are exempt from unemployment insurance. Contribution is calculated on the contractual salary, capped at 20× the base salary.
Two US tax traps here:
- Employer contributions are taxable US income under §402(b). Because there is no US-Vietnam treaty to defer taxation of Vietnamese employer retirement/insurance contributions, the 17.5% social insurance contribution made by your Vietnamese employer on your behalf is treated as additional compensation under IRC §402(b) — taxable to you in the year it vests, not when you eventually receive benefits. You pay Vietnamese PIT on your gross salary; you also pay US tax on the employer SI contributions as compensation. You cannot use the FTC to offset this additional US tax because Vietnamese SI is not an income tax — it is a payroll contribution, and only income taxes (or taxes imposed in lieu thereof) are FTC-creditable under §901.5
- Employee SI contributions are not FTC-creditable. The 9.5% you pay personally to Vietnamese social insurance is not a creditable foreign tax — it is a premium for social insurance benefits, not an income tax. You get no US tax credit for it.
The practical result: for a US citizen earning VND 46,800,000/month (roughly $22,400/year, the SI cap), the employer contributes ~VND 9,594,000/month (~$4,597/year) to SI. This is treated as additional US compensation — adding roughly $4,600 to your US taxable income on which you owe US tax at your marginal rate. At the 22% US bracket, this creates approximately $1,011 in extra annual US tax that cannot be offset by FTC.
5. PFIC Traps in Vietnamese Investments
Vietnam's investment fund industry has grown substantially, with dozens of open-end mutual funds (quỹ đầu tư mở), balanced funds, and index-tracking products available. Every one of them is a Passive Foreign Investment Company (PFIC) under IRC §1297 for US citizen investors.6
PFIC traps in Vietnam include:
- Vietnamese mutual funds (quỹ đầu tư chứng khoán) — including funds managed by VinaCapital, Dragon Capital, Manulife Vietnam, and other domestic managers. All PFICs.
- Open-end ETFs on HOSE/HNX — VFMVN30 and similar Vietnam-domiciled ETFs. PFICs.
- Bancassurance investment products — VietLife, AIA Vietnam, Manulife endowment-linked products. Likely PFICs, with possible Form 3520 foreign trust complications depending on structure.
- Unit-linked insurance plans (ULIPs) offered by Vietnamese insurers — PFIC exposure in the investment component.
The §1291 default regime on PFICs is punishing: excess distributions and gains are allocated back over the holding period, taxed at ordinary rates (not LTCG rates), and then subjected to an interest charge currently around 7% compounded per year of holding. On a fund held for 10 years with a meaningful gain, the effective tax rate can exceed 60%.
The safe harbor: hold US-domiciled ETFs (Vanguard, iShares, Schwab) in a US brokerage account. Vietnamese company stocks held directly on HOSE via a securities account are direct equity — not automatically PFICs — but the practical access for US persons is limited and requires careful FBAR/Form 8938 reporting. If you already hold Vietnamese funds, consult a specialist before selling — the exit strategy (QEF retroactive election where available, MTM election, or planned disposal) affects the tax cost substantially. Our PFIC calculator can estimate the cost of the §1291 default regime on existing holdings.
6. Self-Employment Tax: No Totalization Agreement
Vietnam and the United States do not have a totalization agreement (also called a Social Security Totalization Agreement).7 For US citizens in Vietnam who are self-employed, independent contractors, or receive 1099-type income from US clients, this creates a significant and unavoidable cost:
- Full US self-employment tax applies: 15.3% on the first $184,500 of net SE income in 2026 (12.4% Social Security + 2.9% Medicare), plus 2.9% Medicare on any amount above $184,500.8
- The FEIE does not eliminate SE tax — it only reduces income tax. IRC §1402(a)(8) explicitly preserves SE tax liability for expats even when all earned income is excluded from gross income.
- Vietnamese social insurance contributions you paid cannot be credited against US SE tax.
- No mechanism exists to combine Vietnamese social insurance quarters with US Social Security quarters for benefit eligibility.
For a US freelancer netting $120,000/year from remote work in Vietnam: US SE tax ≈ $16,955 (on $184,500 cap × 15.3% pro-rated). This is effectively unavoidable without restructuring into an entity. Options that reduce SE tax exposure — S-corporation election, foreign corporation check-the-box — each create their own complexity. See our self-employed expat tax guide for a full comparison.
7. Vietnamese Business Ownership: CFC Rules
Many US expats in Vietnam start or co-own Vietnamese businesses, typically structured as Công ty TNHH (LLC-equivalent) or Công ty Cổ phần (joint-stock company). If US persons collectively own more than 50% of the voting power or value of a foreign corporation, that entity is a Controlled Foreign Corporation (CFC) under IRC §957, triggering substantial US tax obligations:
- Form 5471 required annually — penalties for non-filing run $10,000–$60,000 per year per CFC, assessed on the shareholder, not the corporation.
- Subpart F income (Subpart F FPHCI) — passive income (dividends, interest, rents, royalties) earned by the CFC is taxable to US shareholders immediately, regardless of whether it is distributed. Vietnam's 5% withholding on dividends from CFC to a US individual is creditable FTC (passive basket).
- NCTI (formerly GILTI, renamed by OBBBA effective January 2026) — active business profits of the CFC are subject to NCTI inclusion at the US shareholder level. The high-tax exception (18.9% effective rate) can exclude NCTI if the Vietnamese corporate tax rate (20% standard CIT rate) is paid in full — Vietnam's 20% standard rate exceeds the 18.9% threshold, so NCTI can often be excluded via the high-tax exception if all active income is taxed at the full Vietnamese CIT rate.
- §962 election — US individuals can elect to be taxed on Subpart F/NCTI inclusions at corporate rates (~21%) rather than individual rates (up to 37%), and claim a deemed-paid FTC on Vietnamese taxes paid by the CFC.
Vietnam's standard corporate income tax rate is 20% (2026). Preferential rates (10%, 15%, 17%) apply to certain qualifying industries and enterprise zones. A US expat who runs an active Vietnamese business through a properly structured CFC and pays full Vietnamese CIT at 20%+ can often exclude NCTI via the high-tax exception — but the mechanics require annual Form 5471 compliance and a careful elections strategy. This is not DIY territory.
8. Foreign Property: 50-Year Leasehold and §121
Vietnamese law permits foreigners to own apartment units (condominiums) and residential buildings — but not land. The ownership is structured as a 50-year use right, renewable upon expiration, under Vietnam's Law on Housing (amended 2023).9 Foreign ownership is limited to 30% of units per building and 250 units per ward-level administrative zone.
US tax considerations for expat property in Vietnam:
- IRC §121 exclusion (principal residence): The $250,000/$500,000 gain exclusion has no geographic restriction and applies to foreign primary residences. However, §121 requires "ownership" for two of the five years before sale. Whether Vietnam's 50-year renewable use right qualifies as ownership under US law is unsettled — a specialist should review your specific situation before you sell. A 50-year renewable leasehold recognized under Vietnamese law is likely treated as ownership for US purposes, but there is limited IRS guidance on this exact structure.
- Currency gain on VND mortgage: If you take a VND-denominated mortgage to purchase, repayments convert VND back to USD. Any appreciation in USD terms on those principal repayments is taxable as ordinary income under IRC §988. Most expatriates in Vietnam do not take VND mortgages — many transact in USD — but if you do, track the exchange rates at drawdown and repayment.
- Rental income: US-taxable on a net basis (expenses deductible). Vietnamese withholding tax on rental income paid to a foreigner (10%) is FTC-creditable in the passive income basket, subject to the §904 limitation.
- No §1031 exchange for foreign property: TCJA 2017 eliminated §1031 like-kind exchange for all real property that is not US property. Swapping a Vietnamese apartment for another foreign property — or for a Vietnamese property after returning to the US — does not qualify.
9. FBAR, FATCA, and Vietnamese Bank Accounts
Vietnam signed a FATCA Model 1B Intergovernmental Agreement with the US, in force July 7, 2016.10 Vietnamese banks (Vietcombank, BIDV, Agribank, Techcombank, VPBank, and branches of HSBC, Standard Chartered, etc. operating in Vietnam) report US account holders to the Ministry of Finance for transmission to the IRS.
US reporting obligations for Vietnam-based accounts:
- FBAR (FinCEN Form 114): Required if the aggregate maximum value of all foreign financial accounts exceeds $10,000 at any point during the year. FBAR covers Vietnamese bank accounts, brokerage accounts, and any financial account in which you have a financial interest or signature authority — including employer escrow accounts if you are a signatory. Due April 15 with automatic extension to October 15. Non-willful penalty up to $16,536/year per account (Bittner v. US, 2023); willful penalty up to the greater of $165,353 or 50% of account balance per year.
- Form 8938 (FATCA): Required if specified foreign financial assets exceed $200,000 (single or MFS, last day of year) / $300,000 (at any point) while living abroad, or $400,000/$600,000 (MFJ). File with your 1040. Vietnamese brokerage accounts, investment funds, and employer pension accounts all count.
- Form 8621 (PFIC): Required annually for any PFIC holding, even if no distribution or disposition occurred. Failure to file extends the statute of limitations on your entire return indefinitely.
10. Visa Situation for US Citizens in Vietnam
US citizens entering Vietnam for tourism or short stays can obtain a 90-day multiple-entry e-Visa online for $50.11 This allows up to 90 days per stay with multiple entries. For longer-term stays, the visa landscape is more limited than in Thailand or Indonesia:
- E-visa (tourist/visitor): 90-day multiple-entry, $50. Extendable once in-country; otherwise must exit and re-enter. Suitable for initial scouting or short remote-work periods — but working for a Vietnamese entity on an e-visa is not legally compliant.
- Business visa (DN): Issued for legitimate business visits. Duration up to one year with sponsor letter from a Vietnamese legal entity. Not a work authorization — working for the sponsoring entity requires a work permit.
- Work permit (Giấy phép lao động): Required for foreigners working for Vietnamese employers under labor contracts of 12+ months. Employer applies on your behalf. Triggers mandatory social insurance enrollment. Required for legally compliant employment income.
- No dedicated digital nomad visa: Unlike Thailand (DTV), Indonesia (E33G), or Malaysia (DE Rantau), Vietnam does not offer a formal digital nomad visa as of mid-2026. Remote workers on e-visas exist in a gray area — working remotely for a foreign employer while on a Vietnamese e-visa is not explicitly permitted or prohibited, but creates potential Vietnamese PIT obligations if Vietnam residency is triggered (183 days). Enforcement is limited but not zero.
The 183-day residency trigger applies regardless of visa type. Once you are a Vietnamese tax resident, you owe Vietnamese PIT on worldwide income (employment income from a Vietnamese employer AND income from a foreign employer) at the progressive rates above. Digital nomads working remotely in Vietnam for 183+ days should file Vietnamese PIT returns and report foreign-source employment income, even without a work permit.
11. Pre-Move Checklist for US Citizens Moving to Vietnam
- Sever state tax domicile before departing. California and New York claim domicile until you affirmatively establish it elsewhere. Vietnam has no US-friendly tax agreement to help argue you left. Close bank accounts, update voter registration, redeliver drivers license, establish domicile in a zero-income-tax state if returning to the US eventually. See our state residency guide.
- Elect FEIE on first qualifying return. If you'll pass the 330-day physical presence test in your first year, elect FEIE on Form 2555. If you'll use bona fide residence (12 months in Vietnam), you can elect on any return once established. Don't miss the first-year election window — it affects IRA eligibility planning.
- Liquidate non-US investment funds before arriving. If you hold any foreign-domiciled investment funds (Canadian mutual funds, European UCITS, etc.), sell them before you become a Vietnamese resident and recognize gains at US LTCG rates. Waiting until after residency changes nothing about the funds' PFIC status, but at least you start clean in Vietnam.
- Keep your US brokerage account active. Many US brokerages restrict accounts for non-US residents (Fidelity is restrictive; Schwab International and Interactive Brokers are more accommodating). Identify a broker before you leave and maintain the account for PFIC-safe US-domiciled ETF investing.
- Understand whether SI contributions apply to your role. If your employer uses a short-term contract (under 12 months), SI contributions may not be mandatory — but you will still owe Vietnamese PIT as a resident if you stay 183+ days. Model the §402(b) impact on employer SI before your compensation package is set.
- Decide on IRA strategy before first FEIE year. FEIE kills IRA eligibility for excluded income. If you have $500K+ in a traditional IRA and expect FEIE to zero your US taxable income, the year of your move may be your last chance to make a pre-deductible IRA contribution or your best opportunity for a low-rate Roth conversion. See our Roth conversion calculator.
- Register FBAR obligations from day one. Open a Vietnamese bank account → immediately adds to your aggregate foreign account total. If combined with any other foreign accounts, you may already be over the $10,000 FBAR threshold. Calendar the April 15 filing date.
- If freelancing or self-employed: model the SE tax burden. No totalization agreement means SE tax is unavoidable on the first $184,500 of net SE income. An S-corporation structure (as a single-member LLC electing S-corp) may reduce SE tax by allowing reasonable salary + distribution structure — but requires a US entity and ongoing payroll compliance. Run the numbers before committing to a freelance model in Vietnam.
- Plan Vietnamese business structures carefully. If considering a Công ty TNHH or joint-stock company, build Form 5471 compliance and NCTI/Subpart F analysis into your cost model from the start. The 20% Vietnamese CIT rate supports the NCTI high-tax exception in many cases, but the mechanics require annual specialist attention.
- Get a Vietnamese tax identification number (MST). Required for PIT filing. Your employer typically obtains this for you under a work permit, but if you're self-employed or a long-term visitor, you must register with the local tax department independently.
What a Vietnam-Specialist Expat Advisor Handles
Most US financial advisors decline non-US resident clients. Most Vietnamese advisors cannot handle US tax obligations, PFIC rules, or FBAR compliance. The rare intersection — a US-licensed, fee-only advisor who works with US citizens in Vietnam — manages:
- FEIE vs FTC modeling for your specific income level, filing status, and Vietnamese PIT effective rate
- Social insurance §402(b) tracking: calculating the US taxable employer SI contribution, reporting it correctly, and explaining why you cannot FTC the cost
- PFIC review and cleanup for existing Vietnamese fund holdings — QEF election, MTM election, or planned disposal strategy
- US-PFIC-safe portfolio construction through a US brokerage account while living in Vietnam
- CFC compliance for Công ty TNHH or joint-stock company ownership — Form 5471, Subpart F analysis, NCTI high-tax exception, §962 election
- Self-employment tax planning: entity structure analysis for freelancers, Solo 401(k) funding while FEIE is in use
- State domicile severance before departure and state return analysis after return
- FBAR and Form 8938 compliance for Vietnamese bank accounts, brokerage accounts, and employer SI accounts
- IRA/Roth IRA strategy under FEIE: partial FEIE to preserve IRA room, Roth conversion window planning
- Non-US spouse planning if your partner is Vietnamese (non-citizen spouse gift limit $194K/year in 2026, QDOT trust, FBAR signature authority)
- Pre-departure repatriation tax planning when the Vietnam chapter ends: PFIC cleanup, final-year FEIE proration, Roth conversion window before returning to US residency
Get matched with a Vietnam-specialist expat advisor
Fee-only advisors who focus on US citizens in Vietnam and Southeast Asia — not generalists, not commission-based. Free match.
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- Vietnam Personal Income Tax Law (amended), enacted December 2025, effective January 1, 2026. New five-bracket schedule (5/10/20/30/35%) with personal deduction VND 15.5M/month and dependent deduction VND 6.2M/month. Source: Acclime Vietnam, "Vietnam's New Personal Income Tax Law in 2026" (vietnam.acclime.com); KPMG GMS Flash Alert 2026-040 (kpmg.com). Vietnamese tax residents: ≥183 days in calendar year, or registered permanent residence / rental arrangement ≥183 days. Non-residents: flat 20% on Vietnam-sourced income.
- IRS Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad. 2026 FEIE limit $132,900, per IRS Notice 2025-67 (inflation adjustment). irs.gov/publications/p54. IRC §911(a)(1); Form 2555 instructions (2026).
- US-Vietnam income tax treaty signed 2015; as of 2026 not ratified by the US Senate and not in force. IRS A-to-Z treaty list does not include Vietnam as a treaty country with a ratified, in-force agreement: irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z. Confirmed by Acclime Vietnam double tax agreements guide (vietnam.acclime.com/guides/double-tax-agreements/).
- Vietnam Decree 143/2018/ND-CP (Oct 15, 2018): mandatory social insurance for foreign employees with work permits and labor contracts ≥12 months. Contribution rates per Circular 06/2021/TT-BTC and 2026 guidance: employer 17.5% (SI) + 3% (HI) = 20.5%; employee 8% (SI) + 1.5% (HI) = 9.5%. Foreign employees exempt from unemployment insurance. Contribution cap VND 46,800,000/month (20× base salary in 2026). Source: Acclime Vietnam HR & Payroll Guide 2026; eiv.edu.vn/en/what-is-the-social-insurance-contribution-rate-for-foreigners/
- IRC §401/§402(b) employer contribution treatment. IRC §901(a) FTC eligibility requires a tax "imposed in lieu of a tax on income" — Vietnamese social insurance is a payroll contribution, not an income tax, and fails this test. Treas. Reg. §1.901-2. IRS Form 1116 instructions.
- IRC §1297 PFIC definition: a foreign corporation is a PFIC if 75%+ of gross income is passive income, or 50%+ of assets produce or are held to produce passive income. Vietnamese-domiciled investment funds and ETFs meet the §1297 test. IRC §1291 (default regime), §1293 (QEF election), §1296 (mark-to-market election). IRS Notice 88-22 (PFIC classification guidance).
- US Social Security Administration — International Programs: Vietnam is not listed among countries with a US totalization agreement. Full list: ssa.gov/international/agreements_overview.html
- IRC §1402(a)(8): FEIE does not reduce net earnings from self-employment for SE tax purposes. 2026 SS wage base $184,500 (per SSA.gov COLA announcement). SE tax rate 15.3% (SS 12.4% + Medicare 2.9%) on earnings up to $184,500; 2.9% Medicare on amounts above; additional 0.9% ACA Medicare surtax for single filers above $200,000. Form 1040-SE instructions (2026).
- Vietnam Law on Housing No. 27/2023/QH15, effective August 1, 2024. Foreign organizations and individuals: may own residential housing including apartments. Ownership period: 50 years, renewable. Quantity limit: 30% of units per building; 250 units per ward. Land not ownable by foreigners (Law on Land No. 31/2024/QH15). IRC §121: 26 U.S.C. § 121; two-of-five-year ownership and use test; no geographic restriction on foreign property. IRC §988: currency gain on VND-denominated debt.
- US-Vietnam FATCA Intergovernmental Agreement (IGA) Model 1B, signed April 1, 2016, in force July 7, 2016. US Treasury FATCA Governments page: irs.gov/businesses/corporations/fatca-governments. FinCEN Form 114 (FBAR): 31 U.S.C. § 5314; 31 CFR 1010.350. Non-willful FBAR penalty per Bittner v. United States, 598 U.S. 196 (2023): per-report basis, up to $16,536/year. Willful penalty: $165,353 or 50% of balance, whichever is greater. Form 8938: IRC §6038D; thresholds per Treas. Reg. §1.6038D-2(a).
- Vietnam e-Visa for US citizens: 90-day multiple-entry, $50, available at evisa.gov.vn. US Embassy Hanoi/HCMC confirmation: vn.usembassy.gov/vietnamese-visas-and-entry-exit/. Work permits: Decree 152/2020/ND-CP on foreign workers in Vietnam, effective February 15, 2021 (as amended). No formal digital nomad visa program in Vietnam as of June 2026.
Tax values verified as of June 2026. Vietnamese PIT rates reflect the new five-bracket system effective January 1, 2026. US values are for US tax year 2026. VND exchange rate of 25,000/USD used for illustration only; actual rates vary. The US-Vietnam income tax treaty was signed in 2015 but remains unratified and not in force. Confirm current treaty status before planning. Consult a specialist for current analysis.