Question about 10-year rule
I found this forum by googling for the Swedish 10-year rule discussed here: https://www.skatter.se/?q=node/6974&page=1
I am stuck in international tax law and I am not sure if I understood everything in that thread correctly. My situation is as follows. I have been living in Sweden since 2013 and I have a large amount of unrealized capital gains (mostly non-Swedish ETFs and mutual funds, few individual stocks). Around 50% of the assets were bought in Germany where I lived before I moved to Sweden. Unfortunately, I never set up a KF account.
In the fall/winter, I will move to the U.S. on a H1B visa. All my assets are PFICs from the U.S. perspective and I want to dispose them and realize my gains. The question that blows my mind is where I realize the gains and how I will be taxed.
I know that I pay 30% when I dispose the assets in Sweden. Then I could just rebuy everything in the U.S., that is U.S. funds and ETFs. That's the worst case. My U.S. tax adviser tells me I could also sell the assets pretty much immediately after arriving to the U.S. and then potentially pay 0% (respectively a much lower tax determined by my income tax rate based on the mark-to-market taxation of PFICs) because as a non-resident alien the U.S. will only tax U.S. income, not foreign income, for the year 2018. Paying 0% seems to good to be true, but she says it's a loophole. However, that is conditional on Sweden, the moment I deregister in Sweden, gives up its tax claims on my unrealized capital gains. Unfortunately, Sweden giving up the tax claim does not seem to be the case generally (see the 10-year rule for unrealized capital gains).
But my understanding from the above thread is that the 10-year rule does not apply to mutual funds and ETFs (and from my google translate understanding of 3:19 Inkomstskattelagen)? Fwiw, I will cut all my ties to Sweden (I own no home, I have no family here).
What about the individual stocks that I have bought before I moved to Sweden, are they subject to the 10-year rule?