How an American Legally Lowers Norway Wealth Tax When Moving There for a Set Number of Years

Written by Hans Goldstein, EA, licensed insurance agent · CA 4273294
Admitted to practice before the IRS
Updated October 2026

This is the plain-English starting page for an American moving to Norway for a few years, then back to the US or on to another country. Each lever links to the page with the detail.

The levers, ranked, in one table

Per $1 million for a single person above the allowance, at the 1.0% rate. Figures from the real estate page.

What is taxed

• Rate and allowance. 1.0% of net wealth above NOK 1.9 million per person in 2026 (1.1% above NOK 21.5 million). Spouses assessed jointly get a double allowance.
• Worldwide. Once you are resident, everything counts, including US accounts. Wealth is measured on December 31.
• When it starts and ends. You become resident with more than 183 days in any 12 months, or more than 270 days in 36 months (skatteloven section 2-1). Residence ends when you take up residence abroad, spend 61 days or fewer in Norway that year and have no home available there (Skatte-ABC U-19).

The levers

1. A primary home at 25%. A home you live in is counted at 25% of market value. A rental unit in your own home is tax-free in Norway if the lease is 30 days or longer and you use at least half the home (section 7-2), and the house keeps its 25% valuation while your own unit is not rented. The US still taxes the rent. See the real estate page.
2. Debt. Debt is deductible, but section 4-19 cuts the deduction in proportion to discounted assets, so a loan is not a free shield. The real estate page has the rule.
3. Life-only DIAs. A life annuity from an insurer never licensed in Norway is not taxable wealth (section 4-2(2), Skatte-ABC F-24-2.1). Checks that start after you leave are not taxed by Norway as income either, and the US-Norway treaty gives the taxing right to the US (Article 18(2)). Details on the 5-year page and in Norwegian at Unngå formuesskatt.
4. Shares and funds at 80%, a holiday home or your US house at about 30%. Modest help, and shares carry an exit tax.
5. Timing. Wealth is measured on December 31, so what you own on that date is what counts. Moving out in a year can remove that year’s base once you are no longer resident.

What does not work

• A Norway-licensed policy. It is taxed on the gain, not outside the base (BFU 19/11 covers a Norwegian insurer).
• Cash-refund or surrender-value features. A death benefit or cash value may be read as savings insurance and taxed as wealth. We show life-only DIAs. No ruling covers it.
• A period-certain SPIA that pays while you live in Norway. Norway taxes each payment at 22% of the gross amount, your own premium included. It usually loses to the bank.
• Anything done only for the tax. Norway has a general anti-avoidance rule (section 13-2) that looks at substance. I found no ruling on a foreign annuity either way. For a large amount, ask Skatteetaten for a binding advance ruling or get a Norwegian adviser’s written view first.

Moving back, or moving on

• Back to the US. Start the DIAs after you leave. Norway never taxes the checks. Norway’s exit tax is aimed at shares and similar assets, not annuities, but ask your adviser about your assets.
• On to another country. Check whether the next country counts annuities. Spain and the Netherlands count them as wealth; Switzerland (Zurich, no surrender value) does not. See the country ranking.
• Buy before you leave the US. US insurers sell to US residents, with a US address and bank account. Since January 1, 2026, federal withholding on payments is mandatory once your address on file is abroad.

The 59½ question: does a DIA have it?

Every case on this page is non-qualified (after-tax) money. For that money, yes: the 10% additional tax in IRC section 72(q) applies to annuity payments taken before 59½ unless an exception applies. The immediate-annuity exception (72(q)(2)(I)) does not cover a DIA, because income starts more than a year after purchase. Payments on or after 59½ are exempt (72(q)(2)(A)), and payments as a life annuity can fall under the substantially equal periodic payment exception (72(q)(2)(D)). Practical rule: start DIA income at 59½ or later. IRA money works differently (section 72(t), and a QLAC must start by 85).

A worked example

A couple, 72 and 71, with $1 million of non-qualified (after-tax) money to place, move to Norway for 10 years. In my model a home with a rental unit wins if they stay for life or die before about 92, and DIAs win if they return to the US and one of them lives past about 92 to 93. The best of both is a home plus a modest DIA slice. See the couple 72 and 71, the couple 70 and 68, the article on what pencils and the calculator. Payouts are modeled, not quotes.

I am a US-licensed insurance agent and do not give Norwegian tax or legal advice. This is education, not tax advice.

Frequently asked questions

Related reading

• Moving to Norway from the US: the hub
• Moving to Norway for 5 years: wealth tax and annuities
• Unngå formuesskatt når du flytter til Norge (norsk)
• Norway wealth tax and real estate: why real estate is king
• Deferred income annuities: who they fit and who should skip
• Case study: couple 72 and 71, $1M home or home plus DIAs
• Case study: parents 70 and 68, 10 years in Norway
• DIA ladder vs real estate calculator
• Wealth tax by country and US annuities

Sources

• Skatteetaten: Wealth tax rates 2026
• Lovdata: Skatteloven chapter 4 (sections 4-2, 4-10, 4-12, 4-16, 4-19)
• Skatteetaten, Skatte-ABC 2025/2026 F-24 Livrenteforsikring (F-24-2.1 wealth, F-24-5.1 income)
• Lovdata: Skatteloven section 7-2 (rent from your own home)
• IRS: United States and Norway income tax convention (Articles 18, 22, 23)
• 26 U.S.C. 72 (exclusion ratio; 72(q)(2)(I) and 72(u)(4) immediate annuity; 72(q)(2)(D) life payments)
• 26 CFR 31.3405(e)-1 (withholding for payees abroad, from January 1, 2026)