If you are a Bulgarian tax resident investing in US stocks and you have never filed Form W-8BEN with your broker, the IRS has been withholding 30% on every dividend you have received. The treaty between the US and Bulgaria caps that withholding at 10% for portfolio investors - meaning you have been paying three times the treaty rate, indefinitely, on every dividend since you opened the account.
On a $40,000 US equity position yielding 2%, the difference between 30% and 10% withholding is $160 per year. Compounded over a decade of regular investing, that is real money - and it disappears permanently because Bulgaria’s foreign tax credit mechanism only gives you credit for taxes you were actually obligated to pay under the treaty, not for excess withholding you failed to prevent.
The fix is straightforward: file W-8BEN with your broker and claim the treaty rate. But there is more to the Bulgaria picture than the form. The Art. 13(1)(3) ZDDFL exemption on capital gains, the 5% Bulgarian dividend tax on US-source dividends, and the interaction between US withholding and Bulgaria’s foreign tax credit all shape what you actually keep - and a few of the Bulgaria-specific terms below (ZDDFL, EOOD, précompte-style withholding logic) are worth a quick look in our glossary if they’re unfamiliar. This guide works through each of them.
Meet Elena Georgieva. Elena is 38, a software architect in Sofia, and has been investing in US ETFs and individual tech stocks through an IBKR account for three years. She filed W-8BEN when she opened the account - correctly. What she has not done is claim the Art. 13(1)(3) ZDDFL exemption on her capital gains from EU-regulated market disposals. She also does not know whether her US dividends are subject to 5% Bulgarian tax on top of the 10% US withholding - or whether the foreign tax credit covers the full 10%.
Elena’s situation covers the most common questions Bulgarian investors have. If you want to see how your own situation compares, our investor profiles tool walks through similar scenarios by country and account type. This guide answers them.
The Treaty at a Glance
The Convention between the United States of America and the Republic of Bulgaria for the Avoidance of Double Taxation was signed on February 23, 2007, with an amending Protocol signed on February 26, 2008. The treaty entered into force on December 15, 2008, and applies to all tax years since.
| Income Type | Treaty Rate (US Withholding) | Bulgarian Domestic Tax | Notes |
|---|---|---|---|
| Dividends (portfolio, under 10% voting power) | 10% | 5% (gross amount) | Treaty caps US withholding at 10%; Bulgaria taxes the net |
| Dividends (qualifying: 10%+ voting power) | 5% | 5% | Company investor; relevant for EOOD owners holding US stocks |
| Interest | 5% | 8% (deposit interest) | Domestic BG rate reduced by treaty |
| Royalties | 5% | 10% | Reduced from domestic 10% |
| Capital gains (shares) | Residence country only | 10% flat (or exempt under Art. 13 ZDDFL) | No US withholding on sale proceeds for non-US persons |
Sources: US-Bulgaria Tax Treaty (February 23, 2007, force December 15, 2008); Innovires Legal 2026; TaxRavens Bulgaria 2026; IRS Technical Explanation of the Bulgaria Convention.
The treaty’s most important feature for individual investors in US stocks is the combination of the 10% US withholding cap on dividends and zero US withholding on capital gains. Bulgaria then taxes both - but the foreign tax credit prevents most double taxation on dividends. For a visual comparison across all US treaty countries, our tax map tool lays out the rates side by side.
Dividends: Two Layers of Tax, One Credit
What happens to US dividends for a Bulgarian resident
When Elena receives a dividend from a US stock or ETF, two tax systems engage simultaneously.
US side: The IRS requires her broker to withhold tax at source. Without a W-8BEN on file, withholding defaults to 30%. With a valid W-8BEN claiming the treaty, withholding is reduced to 10% (the portfolio rate under Article 10 of the treaty). That 10% is deducted before the dividend reaches her account.
Bulgarian side: Under Art. 38(1) and Art. 46(3) of the Personal Income Tax Act (PITA), dividend income received by a Bulgarian resident individual is subject to a final withholding tax of 5% on the gross amount, regardless of source. This applies to US dividends just as it applies to Bulgarian dividends.
The Foreign Tax Credit
Bulgaria’s tax credit mechanism (ordinary credit method) allows Elena to credit foreign tax actually paid against Bulgarian tax on the same income, up to the Bulgarian tax due on that income.
Worked example:
| Amount | |
|---|---|
| US gross dividend | $1,000 |
| US withholding at 10% (treaty rate) | -$100 |
| Net received from broker | $900 |
| Bulgarian tax at 5% on $1,000 gross | $50 |
| Foreign tax credit (limited to BG tax) | -$50 |
| Additional Bulgarian tax owed | $0 |
| Total effective tax | $100 (10% US, 0% BG net) |
The foreign tax credit absorbs the Bulgarian 5% because the US withholding of 10% already exceeds it. Elena pays 10% in total - the US keeps it all, Bulgaria keeps nothing additional. She does not recover the excess 5% (the difference between the 10% US withholding and the 5% Bulgarian tax). It is simply a cost of investing in US equities as a Bulgarian resident. To model this against your own dividend income, our investment calculators tool runs the withholding and credit math for different treaty rates.
What happens if W-8BEN is not on file:
| Amount | |
|---|---|
| US gross dividend | $1,000 |
| US withholding at 30% (no treaty) | -$300 |
| Net received | $700 |
| Bulgarian tax at 5% gross | $50 |
| Foreign tax credit (limited to BG tax on same income, max 5%) | -$50 |
| Additional Bulgarian tax | $0 |
| Excess US withholding unrecoverable | $250 |
Without W-8BEN, Elena has paid 30% to the US and can only credit 5% back through Bulgaria’s foreign tax credit. The remaining 25 percentage points of overpaid withholding is gone - there is no Bulgarian refund mechanism for excess US withholding, and claiming a US refund as a non-resident requires filing Form 1040NR, which is both complex and not guaranteed.
File the W-8BEN. It is the single highest-value action a Bulgarian investor in US stocks can take.
W-8BEN: What It Is, How to File, When It Expires
What the form does
Form W-8BEN is the IRS’s Certificate of Foreign Status for Beneficial Owners. Filing it with your US broker does two things: it certifies you are not a US person (removing the default 30% withholding obligation), and it claims the reduced treaty rate applicable to your country of residence.
How to file
Most US brokers - IBKR, Firstrade, Saxo Bank - include W-8BEN completion in the account opening process for non-US clients. If you haven’t picked a broker yet, our broker finder tool can match you to platforms that serve Bulgarian residents, our broker cost calculator compares fees across them, and our guide to opening a US brokerage account as a non-resident walks through the process. If you opened an account without completing it, you can file it through the broker’s document centre or by contacting support. The form asks for your name, country of residence, tax identification number (Bulgarian personal number - EGN or LNCH), and the treaty article you are claiming.
For Bulgarian residents claiming the reduced 10% dividend rate, you reference Article 10 of the US-Bulgaria treaty. The current W-8BEN form and instructions are published by the IRS at irs.gov/forms-pubs/about-form-w-8-ben - it is worth checking this directly before filing, since the form is periodically revised and broker-provided versions can lag behind the latest IRS release.
Expiry and renewal
W-8BEN is valid for three calendar years from the date it is signed. A form signed in January 2024 expires at the end of 2026. When it lapses without renewal, the broker reverts to 30% withholding automatically. Most brokers send renewal reminders, but it is your responsibility to act on them.
Practical step: Check your most recent dividend statement from your broker. The withholding rate applied to each dividend is shown. If you see 30%, your W-8BEN is missing or expired. If you see 15%, your W-8BEN is on file but is claiming the wrong rate - some brokers default to the 15% rate used by many major treaties rather than the 10% Bulgaria-specific rate. Verify the form explicitly claims the Article 10 rate under the US-Bulgaria treaty.
Capital Gains: The Art. 13 ZDDFL Exemption
US withholding on capital gains: zero
Unlike dividends, the US does not withhold tax on capital gains from stock sales by non-US persons. When Elena sells a US stock or ETF through her IBKR account, the proceeds are credited to her account without any US deduction. The W-8BEN she filed confirms her non-US status and prevents any US withholding on sale proceeds. Gains still need to be converted from USD to BGN at the transaction-date exchange rate for Bulgarian reporting - our multi-currency accounts guide covers how brokers handle that conversion.
Bulgarian tax on capital gains from US stocks
Bulgaria taxes capital gains from the sale of shares at a flat 10% on the net gain (gross proceeds minus acquisition cost). This applies to US-listed stocks and ETFs held through a brokerage account. Elena’s gain on her US technology stocks is Bulgarian taxable income at 10%.
Note: a flat 10% deductible for expenses is allowed, reducing the effective rate to 9% in practice (accountancybulgaria.com, 2025).
The Art. 13(1)(3) ZDDFL exemption
Art. 13(1)(3) of the Personal Income Tax Act (ZDDFL) provides a full exemption from Bulgarian capital gains tax for disposals of shares traded on regulated markets in the EU/EEA.
Important note on holding period: Innovires Legal’s 2026 guides state explicitly that the regulated-market exemption requires shares to be held for more than 24 months. Other sources, including Ruskov und Kollegen and accountancybulgaria.com, describe the exemption without mentioning any holding period condition - which is not the same as confirming no such condition exists; it may simply be a detail those sources omitted. Given that ambiguity, consult a Bulgarian tax advisor before assuming the exemption applies to a short-term EU market disposal. Treating the 24-month condition as applicable is the more conservative and legally safer assumption until confirmed otherwise.
The key question for US stock investors: Does this exemption cover disposals of US-listed stocks (NYSE, NASDAQ)?
Sources conflict on this point in a way that matters for anyone holding US stocks directly. Innovires Legal’s 2026 trader guide defines the exemption strictly around MiFID II “regulated markets” in the EU/EEA and does not extend it to US exchanges for individuals. Separately, PwC’s Bulgaria Tax Summaries note that, as of January 1, 2021, the exemption was extended to disposals on “equivalent third-country stock markets” as defined under EU Directive 2014/65/EU - and NYSE and NASDAQ are generally treated as equivalent markets under that framework. However, available commentary on this extension (including third-party forum discussion citing the PwC position) describes it as applying to corporate investors, not individuals - which would mean it does not help a personal investor like Elena even if the third-country language sounds broad enough to.
Given this conflict between primary and secondary sources, this is a question to resolve with a Bulgarian tax advisor before filing, not one this guide can answer definitively for individual investors. Treating NYSE/NASDAQ disposals as taxable at 10% (the safer, more conservative position) is the approach taken throughout the rest of this guide, but an advisor may be able to confirm the equivalence extension applies to your specific situation.
Where the exemption does apply for investors with mixed portfolios: disposals of shares traded on EU-regulated markets (Euronext, Deutsche Borse, etc.) and ETFs listed on those markets qualify - subject to the potential 24-month holding period. An investor holding both EU-listed ETFs and US-listed ETFs through the same brokerage account needs to track the two categories separately.
Worked example - two disposals, same year:
Elena realizes two capital gains in 2026: a $10,000 gain selling a NASDAQ-listed tech stock she has held for four years, and a €10,000 gain selling shares in an Euronext-listed ETF she has held for three years.
| NASDAQ disposal | Euronext disposal | |
|---|---|---|
| Gross gain | $10,000 | €10,000 |
| Market type | US exchange | EU-regulated market |
| Holding period | 4 years | 3 years (over 24 months) |
| Conservative treatment | Taxable | Exempt under Art. 13(1)(3) |
| Expense deduction (10%, if taxable) | -$1,000 | n/a |
| Taxable base | $9,000 | $0 |
| Bulgarian tax at 10% | $900 | $0 |
| Effective rate on gross gain | 9% | 0% |
On the conservative reading used throughout this guide, the NASDAQ gain costs Elena $900 in Bulgarian tax (effectively 9% of the gross gain), while the Euronext gain - held past the 24-month mark on an EU-regulated market - is fully exempt under Art. 13(1)(3), regardless of size. The entire €10,000 is hers. For a real-world look at how multi-year holding periods play out for US-listed positions, see our TQQQ recovery case study.
If a Bulgarian tax advisor confirms that the third-country equivalence extension does apply to Elena’s NASDAQ disposal, the $900 would not be owed either. Until that is confirmed for her specific situation, planning around the $900 liability is the safer assumption.
Elena’s situation: Her US tech stocks are traded on NASDAQ. Taking the conservative position, capital gains from those disposals are taxable in Bulgaria at 10% (effective 9% after expense deduction) - though she should ask her tax advisor whether the third-country equivalence extension might apply to her personally. Her EU-listed ETF disposals may be exempt under Art. 13(1)(3) - subject to confirming the holding period question with her tax advisor.
Interest Income from US Sources
The US-Bulgaria treaty caps US withholding on interest at 5% (Article 11). For Bulgarian residents receiving interest from US Treasury bonds or US money market instruments held directly, a W-8BEN claiming the treaty reduces withholding from the default 30% to 5%.
On the Bulgarian side, interest income from deposits is taxed at 8% in 2026. Interest from US bonds held as investment instruments is typically taxed as ordinary income at the 10% flat rate. The foreign tax credit applies - the 5% US withholding credits against Bulgarian tax on the same income.
For most retail investors, this is a secondary concern. Bond ETFs held as US-domiciled funds pay distributions typically classified as ordinary dividends at the fund level - not interest - which means the 10% dividend withholding rate applies rather than the 5% interest rate. The classification depends on the fund’s distribution characterization on Form 1042-S.
Tax Return Filing in Bulgaria
Annual deadline and form
Bulgarian residents with investment income must file an annual personal income tax return by April 30 of the following year (April 30, 2027 for the 2026 tax year). The return is filed with the National Revenue Agency (NRA) via the NAP portal or in person at regional tax offices.
Early filers who submit before March 31 and pay online receive a 5% reduction on the tax due, capped at BGN 500 (approximately EUR 255). For investors with meaningful capital gains, this is a real saving worth the timing effort.
What to report
- US dividends received: Report the gross amount on Form 201 (Annex 8 for foreign income, in the 2025 tax year form). Claim the foreign tax credit for the 10% US withholding actually deducted.
- Capital gains from US stocks: Report on Form 201 (typically Annex 5 for capital gains, in the 2025 tax year form), taxable at 10% (effective 9%). Calculate gain as sale proceeds minus acquisition cost, in BGN at the BNB exchange rate on the transaction dates.
- Capital gains from EU-regulated market stocks: Report on Form 201, claim the Art. 13(1)(3) exemption (subject to holding period confirmation).
A note on annex numbers: Annex numbering on Form 201 has shifted between tax years in the past. Verify the current annex number for foreign dividend income and capital gains on the NAP portal (nra.bg) before filing for the 2026 tax year, rather than relying on the numbers above.
- Form 1042-S: Your US broker issues this by March 15 documenting US-source dividends and withholding. This is your primary document for the Bulgarian foreign tax credit calculation. Keep it.
What not to miss
The foreign tax credit must be actively claimed - it does not apply automatically. If Elena does not claim the Art. 13(1)(3) exemption and the dividend foreign tax credit on her return, she pays double tax on both. The NRA does not apply treaty provisions on her behalf.
The EOOD Structure: For Business Investors
Some Bulgarian investors hold US stocks through an EOOD (single-member limited liability company) rather than personally. The tax chain is different.
An EOOD pays 10% Bulgarian corporate income tax on trading profits. Dividends distributed from the EOOD to the individual owner face an additional 5% Bulgarian dividend withholding. The combined effective rate is 15%.
For US-source dividends received by an EOOD: the EOOD is a legal entity, not an individual. The W-8BEN form for individuals does not apply. The entity must file Form W-8BEN-E with the US broker to claim the treaty rate. The relevant treaty rate for an entity holding less than 10% voting power in the US payer is the portfolio rate - the treaty text at Article 10 applies to “beneficial owners” that are residents of Bulgaria, which includes Bulgarian legal entities.
The Art. 13(1)(3) ZDDFL exemption applies only to individuals under PITA. An EOOD’s capital gains from US stock disposals are taxed at 10% corporate income tax, with no regulated-market exemption available.
The EOOD is not tax-efficient for passive US stock investing compared to personal holding, primarily because of the 15% combined rate versus the 10% dividend withholding under treaty for individuals, and the loss of the Art. 13 exemption. It may make sense for other business reasons, but not for the tax treatment of US investment income alone.
How the US-Bulgaria Treaty Compares
| Country | US Dividends (Portfolio) | Interest | Capital Gains |
|---|---|---|---|
| Bulgaria | 10% | 5% | Residence only |
| Australia | 15% | 10% | Residence only |
| Austria | 15% | 0% | Residence only |
| Czech Republic | 15% | 0% | Residence only |
| Denmark | 15% | 0% | Residence only |
| China | 10% | 10% | Residence only |
| United Kingdom | 15% | 0% | Residence only |
| Japan | 10% | 0% | Residence only |
Bulgaria’s 10% portfolio dividend rate is one of the most competitive in the major US treaty network - matching Japan and China and better than the UK, Austria, Czech Republic, and Australia’s 15%. The 5% interest withholding is less competitive than Austria, the Czech Republic, and the UK (all 0%), but better than China and Australia’s 10%.
The combination of the 10% US withholding and Bulgaria’s 5% flat domestic dividend tax - effectively neutralized by the foreign tax credit - produces a total effective rate of 10% on US dividends for Bulgarian residents. That is among the lowest effective rates available to any non-US investor in the treaty network.
Common Mistakes That Cost Bulgarian Investors Money
Not filing W-8BEN at account opening. Defaults to 30% withholding. Costs $160 per year on a $40,000 US portfolio at 2% yield. Check your dividend statements: look for 10%, not 15% (wrong treaty rate) and not 30% (no treaty).
Letting W-8BEN expire. Valid three calendar years from signing. Reverts automatically to 30% without notice. Set a reminder.
Assuming the Art. 13 exemption clearly applies to US-listed shares without checking. The exemption is built around EU/EEA regulated markets, and the conservative position is that NYSE and NASDAQ disposals are taxable at 10%. But sources conflict on whether a third-country equivalence extension reaches individual investors trading on US exchanges. Confirm your position with a Bulgarian tax advisor before filing rather than assuming either way - an incorrect claim on Form 201 can trigger NRA review.
Not claiming the Art. 13 exemption on EU-listed shares. The reverse error. Paying 10% on gains from Euronext or Deutsche Borse disposals when they may be fully exempt (subject to the holding period question).
Not claiming the foreign tax credit. The 10% US withholding on dividends can offset the 5% Bulgarian tax on the same income. Failing to claim it means paying Bulgarian tax that the credit would eliminate.
EOODs filing W-8BEN instead of W-8BEN-E. Legal entities must file the entity form. Using the individual form means the broker may not apply the treaty rate and may revert to 30%.
Not filing Form 201 at all. For US-source income - dividends and US-market capital gains - a return is required regardless of whether some income is exempt.
Practical Checklist
Bulgarian resident investing in US stocks (individual account):
- Confirm W-8BEN is on file - check dividend statements for 10%, not 30% or 15%
- Verify the form explicitly claims Article 10 of the US-Bulgaria treaty
- Renew W-8BEN before the three-year expiry date
- File Form 201 with the NRA by April 30 (or March 31 for the 5% early-filing discount)
- Report US dividends as foreign income and claim the foreign tax credit for the 10% US withholding
- Report capital gains from US-listed stocks as taxable at 10% (the conservative position - confirm with a tax advisor whether the third-country equivalence extension applies to your situation before assuming otherwise)
- Consult a Bulgarian tax advisor on the holding period condition for the Art. 13(1)(3) exemption on EU-listed shares before claiming it
- Keep your Form 1042-S (issued by US broker by March 15) as the primary document for dividend and withholding records
Bulgarian investor using an EOOD to hold US stocks:
- File W-8BEN-E (entity form) not W-8BEN (individual form) with your US broker
- Note that the Art. 13(1)(3) ZDDFL exemption does not apply to the EOOD
- Combined effective rate on EOOD dividends distributed to the owner: 15%
- Consider whether personal holding is more tax-efficient for pure US stock investment
US citizen living in Bulgaria:
- File Form 1040 annually - the US taxes worldwide income
- Claim Foreign Tax Credit (Form 1116) for Bulgarian taxes paid
- File FBAR (FinCEN 114) if aggregate Bulgarian account balances exceed $10,000 at any point
- File Form 8938 if total foreign financial assets exceed $200,000 at year-end or $300,000 at any point (single filer abroad)
- If EOOD owner: file Form 5471 annually - penalty for non-filing is $10,000
- Note: no US-Bulgaria totalization agreement exists as of 2026
Key Takeaways
Bulgaria’s treaty with the US delivers one of the most competitive withholding rates in the major treaty network. The 10% portfolio dividend rate, combined with Bulgaria’s 5% domestic dividend tax and a foreign tax credit that neutralizes the Bulgarian layer entirely, produces a 10% total effective rate on US dividends. That is better than Germany, the UK, and Australia - all at 15%.
The capital gains picture requires careful tracking by market type. There is zero US withholding on stock sale proceeds for non-US persons, and a potential full exemption under Art. 13(1)(3) ZDDFL for EU-regulated market disposals (subject to a possible 24-month holding period - confirm with a tax advisor). For US-listed stocks, the conservative position is that they fall outside this exemption and are taxable at Bulgaria’s flat 10% rate (effectively 9% after the standard expense deduction) - but PwC’s Bulgaria Tax Summaries note a third-country equivalence extension since 2021 that may reach NYSE and NASDAQ disposals, with conflicting commentary on whether it applies to individuals or only corporate investors.
The practical priorities are: file W-8BEN correctly at the 10% Article 10 rate, understand which of your holdings qualify for the Art. 13 exemption and which do not, and claim the foreign tax credit on your annual return.
This article is informational only and does not constitute tax or legal advice. Treaty rates are based on the Convention between the United States and the Republic of Bulgaria for the Avoidance of Double Taxation (signed February 23, 2007, in force December 15, 2008) and the amending Protocol (February 26, 2008). Bulgarian domestic tax rates reflect the Personal Income Tax Act (ZDDFL) and Corporate Income Tax Act (CITA) as in force for the 2026 tax year. The Art. 13(1)(3) ZDDFL holding period condition is disputed between sources - consult a qualified Bulgarian tax advisor before relying on the exemption. Always consult a qualified cross-border tax professional for advice specific to your situation.
Sources: US-Bulgaria Income Tax Convention and Protocols (US Treasury, 2007-2008); IRS Technical Explanation of the Bulgaria Convention; Innovires Legal - Bulgaria-US Double Tax Treaty guide (April 2026); Innovires Legal - Bulgaria trader tax guide (April 2026); TaxRavens - Bulgaria Personal Taxation 2026 (February 2026); PwC Tax Summaries - Bulgaria Individual Income Determination (2026); PwC Tax Summaries - Bulgaria Corporate Withholding Taxes (2026); Ruskov und Kollegen - Taxes on trading with shares in Bulgaria (February 2025); accountancybulgaria.com - Taxation of Trading in Bulgaria (2025); IRS Publication 515 (2026); FinCEN FBAR guidance (2025).
Frequently Asked Questions
What is the US withholding tax rate on dividends for Bulgarian residents? 10% under Article 10 of the US-Bulgaria tax treaty, provided you have filed a valid W-8BEN with your broker claiming the treaty rate. Without W-8BEN, the default rate is 30%.
Do I pay Bulgarian tax on top of the 10% US withholding? Bulgaria imposes a 5% dividend tax on gross dividend income. However, Bulgaria’s foreign tax credit mechanism allows you to offset the 10% US withholding against the 5% Bulgarian tax - eliminating the Bulgarian layer entirely. Your total effective rate is 10%.
Are capital gains from US stocks taxable in Bulgaria? The conservative position is yes: capital gains from US-listed stocks (NYSE, NASDAQ) are taxable in Bulgaria at 10% flat on the net gain, with a 10% standard expense deduction reducing the effective rate to approximately 9%. Some sources point to a third-country equivalence extension that could exempt these disposals, but available commentary suggests this may apply to corporate investors rather than individuals. Confirm your specific position with a Bulgarian tax advisor before assuming either outcome.
Are capital gains from EU-listed shares exempt in Bulgaria? Generally yes under Art. 13(1)(3) ZDDFL, but sources conflict on whether a 24-month minimum holding period applies. Consult a Bulgarian tax advisor before claiming the exemption on short-term positions.
How do I file W-8BEN with my broker? Most international brokers (IBKR, Saxo, Firstrade) include W-8BEN in the account opening process. If not completed at opening, it is available through the broker’s document centre or client portal. Reference Article 10 of the US-Bulgaria treaty. The form is valid for three calendar years and must be renewed before expiry.
Does owning a Bulgarian EOOD change my tax treatment? Yes significantly. An EOOD pays 10% corporate income tax on profits. Dividends distributed to the owner then face an additional 5% withholding - for a combined 15% effective rate. The EOOD must file W-8BEN-E (not W-8BEN) with the US broker. The Art. 13(1)(3) capital gains exemption is not available to EOODs.
Do I need to worry about FBAR or FATCA if I am not a US citizen? No. FBAR (FinCEN Form 114) and Form 8938 (FATCA reporting) are US filing obligations that apply to US citizens, Green Card holders, and certain other US persons - not to a Bulgarian citizen who simply holds a US brokerage account. If you are a Bulgarian tax resident with no US citizenship or Green Card, these filings do not apply to you regardless of your account balance. They become relevant only for US citizens or Green Card holders living in Bulgaria, covered separately in this guide’s checklist - our expat financial planning guide covers the broader cross-border picture for that group.
