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Filing rules · 22 September 2026

US tax for Americans in Norway

There is a US–Norway income tax treaty and a totalization agreement. Norwegian income tax runs to about 47% once the bracket tax is included, so the foreign tax credit usually removes the US liability outright. What it cannot touch is the net wealth tax, which is charged on assets rather than income and sits outside Form 1116 entirely.

A treaty and a totalization agreement both in place, with the wealth tax marked as the charge that credits nothing.
Jorge I. Rivas, EA
Jorge I. Rivas, EA
Enrolled Agent · 6 minutes to read

The bracket tax credits; the wealth tax does not

Norwegian income tax is a flat national rate with the bracket tax, trinnskatt, stacked on top. Both are income taxes and both belong on Form 1116. The net wealth tax is charged on assets rather than income, which puts it outside the taxes the credit recognises.

For a high-net-worth American in Norway that is a real annual cost with no US offset at all — not a timing difference, not a carryforward, simply money that buys nothing on the American return. Keeping the two charges apart is what makes the Form 1116 figure defensible.

The national insurance contribution is not creditable either

Trygdeavgift is social security rather than income tax, so it does not go on Form 1116. It is the totalization agreement that deals with that side, assigning coverage to one country and taking the 15.3% US self-employment charge off a self-employed American covered in Norway — on a certificate of coverage.

A treaty from 1971 does not carry modern provisions

The US–Norway treaty is one of the older ones still in operation. It lacks provisions that a modern treaty would carry, so positions available under the UK or Dutch treaties may simply not exist here — pension articles in particular are thinner than people expect.

That is not a reason for alarm; it is a reason to read the treaty rather than assume it resembles the one a colleague relied on elsewhere.

ASK accounts and Norwegian pensions

A share savings account (aksjesparekonto) defers Norwegian tax on gains inside it. The US does not follow that deferral, and the funds held inside are commonly PFICs — Form 8621, and a default calculation designed to be unattractive.

Norwegian occupational pension arrangements have the same shape of problem. Neither is automatically a US-recognised retirement arrangement, so both need a position taken with the documents in hand.

A worked example, tax year 2025

A single American employed in Oslo on $185,000, with Norwegian income and bracket tax of $85,000 and a wealth tax charge of $6,000. Norwegian figures are illustrative; the US figures are computed.

Salary$185,000
Norwegian income tax and bracket tax — creditable$85,000
Norwegian net wealth tax — not creditable$6,000
US income tax before the credit$33,467
US income tax after the credit$0
Excess credit carried forward$51,533
US relief for the wealth tax paidNone
Income tax and bracket tax together are more than double the US tax on the same income, so the credit removes the liability and $51,533 carries forward. The $6,000 of wealth tax sits outside that entirely — it is not an income tax, so no part of it reduces US tax now or later. Sources: IRC §901 and §904; IRS Publication 514; Rev. Proc. 2025-32.

Scroll the table sideways

FactPosition
US income tax treatyYes — the 1971 treaty
Totalization agreementYes
Local income taxProgressive to about 47% including the bracket tax
Self-employment tax (SECA)Relieved where the agreement covers you
FBAR threshold$10,000 aggregate, any point in the year
Sources

IRC §901, §904 and §911; the 1971 US–Norway income tax treaty; US–Norway totalization agreement; IRS Publication 54; IRS Publication 514; IRS Form 8621 instructions; Norwegian income tax, bracket tax, national insurance contribution and net wealth tax; Rev. Proc. 2025-32; 31 CFR 1010.350. US figures are tax year 2025. Checked 22 September 2026.

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22 September 2026First published
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Questions Americans in Norway ask

Is the Norwegian wealth tax creditable on my US return?

No. It is charged on net assets rather than on income, which puts it outside the taxes Form 1116 recognises. It is a real cost with no US offset, now or by carryforward.

How old is the US–Norway treaty?

It dates from 1971 and is one of the older treaties still operating. It lacks provisions a modern treaty would carry, so positions available under the UK or Dutch treaties may not exist here.

Is the national insurance contribution creditable?

No. Trygdeavgift is social security rather than an income tax. The totalization agreement handles that side, and a certificate of coverage is what removes the US self-employment charge.

Is my ASK tax-deferred for US purposes?

No. Norwegian deferral inside a share savings account does not carry to the US return, and the funds held in one are commonly PFICs — which brings Form 8621 and a harsher default calculation.

I have not filed for several years while in Norway. What now?

If the failure was non-willful — which describes most people in this position — the Streamlined Foreign Offshore Procedures waive the failure-to-file, failure-to-pay and FBAR penalties: three years of returns, six years of FBARs, and Form 14653.

Filing from Norway?

Twenty minutes settles which Norwegian charges actually credit, and what your ASK is doing on the American side.

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