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U.S. Taxes for Americans Living in Hong Kong: The 2026 Guide

How US federal tax rules apply with no US–Hong Kong income tax treaty and no totalization agreement: salaries tax source rules, FEIE vs. the foreign tax credit, the MPF's unsettled trust and PFIC status, and tax clearance when you leave.

Key takeaways

  • US citizens and green card holders in Hong Kong generally keep filing a US return on worldwide income, because US taxation follows citizenship and status, not where you live.
  • Hong Kong taxes on a source basis: salaries tax reaches employment income "arising in or derived from Hong Kong," and there is no general tax on investment income or capital gains.
  • There is no US–Hong Kong income tax treaty and no social security totalization agreement, so relief comes only from US domestic rules such as the foreign tax credit and the Foreign Earned Income Exclusion.
  • Because Hong Kong rates are low (salaries tax is capped by a 15%/16% standard rate), the exclusion plus the housing exclusion often does more than the credit, but the right choice depends on income and housing costs.
  • MPF accounts and Hong Kong-domiciled investment funds raise unsettled US questions, including possible foreign trust and PFIC reporting.

Do Americans living in Hong Kong still file US taxes?

Yes. US citizens and residents living abroad generally file income, estate and gift tax returns the same way as people living in the US. Whether you must file depends on worldwide gross income, filing status and age (IRS Publication 54). Income you plan to exclude under the Foreign Earned Income Exclusion still counts toward the threshold (IRS, Filing requirements page, reviewed Sept. 28, 2026). If you have not filed in past years, see our guide on the Streamlined Filing Compliance Procedures for how to catch up without the usual penalties.

For tax year 2026, the standard deduction is $16,100 for single filers and married filing separately, $32,200 for joint filers and $24,150 for heads of household (IRS release on Rev. Proc. 2025-32, Oct. 9, 2025; indexed annually). With $400 or more of net self-employment earnings, you generally must file regardless (IRC §6017).

Deadlines for tax year 2026:

  • April 15, 2027: regular due date for filing and payment.
  • June 15, 2027: automatic two-month extension to file and pay if, on April 15, you live and have your main place of business or post of duty outside the US and Puerto Rico. Interest runs from April 15.
  • October 15, 2027: further extension to file (not to pay) with Form 4868 filed before June 15 (IRS, Where and When to File and Pay, reviewed Sept. 28, 2026).
  • FBAR (FinCEN 114): due April 15, with an automatic extension to October 15 (FinCEN due-date notice).

When does Hong Kong treat you as a tax resident, and what does it tax?

Residency is mostly beside the point. Hong Kong's main taxes turn on source, not residence. Salaries tax is charged on income from employment "arising in or derived from Hong Kong" (Inland Revenue Ordinance (IRO) s.8(1), as quoted in IRD Departmental Interpretation and Practice Notes (DIPN) No. 10, rev. June 2007). Profits tax reaches only Hong Kong-source profits and does not charge profits from the sale of capital assets (DIPN No. 21, rev. July 2012; IRD, A Brief Guide to Taxes 2025–2026, Oct. 2025). Property tax applies to rent from Hong Kong property. Outside these three charges, Hong Kong generally does not tax an individual's investment income, and dividends from companies subject to profits tax are excluded from assessable profits (Brief Guide). The charging language makes this a territorial system.

Where residence matters. Personal assessment, an optional election that combines your salaries, profits and property income and allows mortgage interest on rental property, is open to people who are "ordinarily resident" or "temporary residents" (more than 180 days in the year of assessment, or more than 300 days over two consecutive years including that year) (Brief Guide). Certificates of resident status for Hong Kong's other treaties do not help with US tax.

Tax residence is not immigration status. Hong Kong "permanent resident" status (right of abode) is an immigration concept and does not decide whether your salary is taxable.

Is your job a Hong Kong employment? The IRD looks mainly at where the contract was negotiated, entered into and enforceable, where the employer is resident, and where you are paid, considering all facts; where you work is not the source test (DIPN 10, paras 2–6).

  • Hong Kong employment: all income is taxable wherever the work is done, unless you render all services outside Hong Kong, ignoring visits of 60 days or less (DIPN 10, paras 25, 31–33).
  • Non-Hong Kong employment: only income for services rendered in Hong Kong is taxable, usually apportioned by days, and it is ignored if your visits total 60 days or fewer in the year. The rule covers visits, not the start or end of a long stay (DIPN 10, paras 28–33).

The official IRO text could not be retrieved from e-Legislation for this guide; the wording above comes from IRD notes.

Rates. Salaries tax is the lower of two calculations (IRD leaflet PAM 39(e), May 2026):

  • Progressive: 2% on the first HK$50,000 of net chargeable income, then 6%, 10% and 14% on each next HK$50,000, and 17% above HK$200,000.
  • Standard: from 2024/25, 15% of net income (before allowances) up to HK$5 million and 16% above.

The basic allowance rises from HK$132,000 (2025/26) to HK$145,000 (2026/27) and the married person's allowance from HK$264,000 to HK$290,000; the law was gazetted May 22, 2026 (IRD, 2026–27 Budget – Tax Measures). Allowances change by budget, not by indexation.

Year and filing. The year of assessment runs April 1 to March 31. Salaries tax is collected by assessment, with provisional tax usually paid in instalments around January and April (PAM 39). Individual returns are generally issued in early May and due within one month, with an extra month for e-filing. Property owners without a return must notify the IRD by July 31 after the year (PAM 54(e), Nov. 2022).

Recent guidance. Final 2025/26 salaries tax, profits tax and personal assessment are reduced by 100%, capped at HK$3,000 per case; provisional tax is not reduced (IRD Budget page). The core source and share-benefit guidance (DIPN 10, 2007; DIPN 38, 2008) is old, and later case law may affect how it applies.

Is there a US–Hong Kong tax treaty?

No. The IRS list of US income tax treaties does not include Hong Kong (IRS, Tax treaties A to Z, reviewed Jan. 3, 2026). The US–China treaty appears separately on that list, and it is generally understood not to apply to Hong Kong, which runs its own tax system. A 1989 exchange of notes on reciprocal shipping income exemption was the subject of a US termination notice in August 2020 under Executive Order 13936; it was never a general income tax treaty.

What that means:

  • No saving clause or tie-breaker. Without a treaty, there is nothing to override: the US taxes citizens and green card holders on worldwide income under the Internal Revenue Code, and Hong Kong taxes Hong Kong-source income under the IRO.
  • No treaty position for green card holders. Unlike in treaty countries, a green card holder living in Hong Kong cannot claim treaty residence elsewhere to limit US tax. Green card holders remain US tax residents until status is formally given up or abandoned.
  • Pensions and dividends. No treaty article allocates pension or dividend taxation. Hong Kong generally does not tax these for individuals (see above); the US taxes them in full.
  • Unilateral relief. Double taxation is relieved on the US side by the foreign tax credit (IRC §901) or the Foreign Earned Income Exclusion (IRC §911), described next.

How do you avoid paying tax twice?

For the general mechanics of these two tools, see our guide on FEIE vs Foreign Tax Credit.

Two US tools exist, and they cannot be used on the same dollar.

  • Foreign Earned Income Exclusion (Form 2555): up to $132,900 for 2026 (Rev. Proc. 2025-32; indexed). It requires bona fide residence or 330 full days abroad in 12 months and does not reduce self-employment tax.
  • Housing exclusion or deduction: costs above a $21,264 base, up to a location limit. For 2026 the Hong Kong limit is $114,300 for a full year, versus a general cap of $39,870 (IRS Notice 2026-25; set annually).
  • Foreign Tax Credit (Form 1116): credit for Hong Kong taxes that qualify as foreign income taxes, by basket. Unused credits generally carry back one year and forward ten (IRC §904(c)). Excluded income cannot also generate a credit.

Which tends to fit. Hong Kong's effective rate on salary is usually below the US rate, so the credit alone often leaves US tax due. The exclusion plus the Hong Kong housing limit frequently removes more income. Income left after the exclusion is taxed at the rates that would apply without it (IRC §911(f)), and revoking the exclusion generally bars re-election for five years without IRS consent (Pub. 54). Some taxpayers exclude salary up to the limit and credit Hong Kong tax on the rest.

The timing mismatch. A foreign tax computed on a foreign tax year generally becomes fixed at the close of that year and accrues in the US year in which it ends; the regulation's example uses a year ending March 31 (Treas. Reg. §1.905-1(d)(1), Example 1). Hong Kong tax for 2026/27 therefore generally accrues on March 31, 2027 and goes on the 2027 Form 1116, though partly computed on 2026 income. Cash-basis taxpayers credit tax when paid unless they elect accrual (IRC §905(a)).

Social security: will you pay both?

There is no US–Hong Kong totalization agreement; Hong Kong does not appear on the SSA's list of agreement countries (SSA, International Agreements). Hong Kong's main compulsory scheme is the Mandatory Provident Fund (MPF), a privately managed retirement savings system, not a social insurance program like US Social Security.

Employees.

  • Hong Kong employer: you generally join the MPF. Employer and employee each contribute 5% of relevant income, within a minimum of HK$7,100 and a maximum of HK$30,000 per month, so the employee share is capped at HK$1,500 a month (MPFA, Mandatory contributions). A US citizen working for a non-US employer outside the US is generally not subject to FICA.
  • American employer: if an American employer sends a US citizen or resident to a country with no totalization agreement, the employer and employee are generally liable for Social Security taxes in both countries (IRS, Totalization Agreements page). In Hong Kong, MPF exemptions may reduce the overlap: people from overseas who enter Hong Kong for employment for not more than 13 months, and people covered by overseas retirement schemes, are listed as exempt persons (IRD DIPN 23, rev. May 2019).

Self-employed. US citizens owe self-employment tax on worldwide net self-employment earnings, and with no agreement there is no certificate of coverage to remove it. The FEIE does not reduce self-employment tax.

Certificate of coverage. None is available for Hong Kong, because certificates exist only under totalization agreements.

Effect on US benefits. Hong Kong MPF participation does not create US Social Security credits, and Hong Kong periods cannot be counted toward US benefits. If you are paying FICA through an American employer, you keep earning US credits.

Which US forms apply to accounts and assets in Hong Kong?

  • FBAR: required if your non-US accounts together exceed $10,000 at any time in the year; not indexed (FinCEN). An MPF account is generally treated as reportable by practitioners.
  • Form 8938: if you live abroad and meet a presence test, required above $200,000 at year-end or $300,000 at any time (single or separate filers), or $400,000 / $600,000 for joint filers; not indexed. A foreign pension plan is reportable as one asset (Form 8938 instructions, rev. 11/2021). The exception for foreign social security does not obviously fit the MPF, which is a privately managed savings scheme.
  • One form does not replace the other.

Hong Kong banks and US persons. Hong Kong and the US signed a "Model 2" FATCA agreement on November 13, 2014. Hong Kong financial institutions register with the IRS and, with the account holder's consent, report US-person accounts directly to the IRS (HK Government press release, Nov. 13, 2014). Expect to self-certify US status.

CRS. Hong Kong financial institutions began CRS due diligence in January 2017, with Hong Kong's first exchanges with partner jurisdictions in September 2018 (IRD, AEOI pamphlet). The US is outside CRS; US-person data flows through FATCA.

Local pensions, retirement accounts and investment funds

MPF and ORSO schemes. For Hong Kong tax, employee mandatory MPF contributions are deductible up to HK$18,000 a year (IRO s.26G, per DIPN 23). The US does not follow that deduction. Several US questions about the MPF are unsettled, and practitioners take different positions:

  1. Is it a foreign trust? If so, Forms 3520/3520-A may apply, unless Rev. Proc. 2020-17 or the proposed section 6048 regulations (May 2024, reliance permitted if applied consistently) exempt it. Neither removes FBAR, Form 8938 or tax (IRS Filing requirements page), and the IRS has not addressed the MPF by name.
  2. Are employer contributions and growth taxable now? Some practitioners treat the MPF as a nonexempt employees' trust (IRC §402(b)), which can mean current taxation of vested employer contributions; others take different views.
  3. Are the underlying funds PFICs? MPF constituent funds are pooled vehicles, and some practitioners treat them as PFICs.

Withdrawals on leaving. MPF benefits may be withdrawn early on permanent departure from Hong Kong. This ground can be used only once, and a false declaration is an offence (MPFA press release, June 16, 2021). The US tax treatment of the withdrawal depends on how you treated the account earlier.

Hong Kong investment funds. A foreign corporation is a PFIC if 75% or more of its income is passive or 50% or more of its assets produce passive income (IRC §1297). Hong Kong-domiciled unit trusts and ETFs are generally treated as PFICs, with punitive default taxation and possible Form 8621 per fund. Individual Hong Kong-listed shares of operating companies usually are not PFICs, though each company must be checked. For how PFIC taxation and elections actually work, see our guide on PFICs Explained.

Running a business or company in Hong Kong

Classification first. A Hong Kong "Public Limited Company" is on the US per se list, and for Hong Kong any limited company not defined as private under local company law counts as public (Treas. Reg. §301.7701-2(b)(8)(i), (iii)). A private company limited by shares is therefore an eligible entity: it may elect its classification on Form 8832, and absent an election defaults to corporation because its members have limited liability (Treas. Reg. §301.7701-3(b)(2)). Disregarded status brings Form 8858 and self-employment tax.

Hong Kong taxes. Profits tax is 8.25% on the first HK$2 million and 16.5% above for corporations, and 7.5% / 15% for unincorporated businesses (Brief Guide). Since January 1, 2023, the foreign-sourced income exemption regime can tax certain offshore passive income of multinational group entities when received in Hong Kong (Brief Guide).

CFC exposure. A corporation more than 50% owned by US shareholders is a CFC: Form 5471, and possible Subpart F and section 951A inclusions. For tax years beginning after December 31, 2025, P.L. 119-21 renamed GILTI "net CFC tested income" (NCTI) and removed the tangible-asset carve-out. With Hong Kong's low profits tax rate, a Hong Kong CFC's income is often currently taxable in the US.

Sole proprietors report on Schedule C, pay Hong Kong profits tax on Hong Kong-source profits, and owe US self-employment tax with no relief.

Buying, renting and selling property

Selling your home. IRC §121 excludes up to $250,000 of gain ($500,000 joint) on a principal residence owned and used for two of the last five years, with no US-location requirement. Gain is measured in dollars.

Hong Kong tax on a sale. Hong Kong does not charge profits tax on the sale of capital assets (Brief Guide). Frequent buying and selling can be treated as trading, which is taxable; whether a sale is capital or trading depends on the facts. The extra residential stamp duties (Special Stamp Duty, Buyer's Stamp Duty and New Residential Stamp Duty) were abolished for transactions from February 28, 2024 (IRD press release, Feb. 28, 2024). Ordinary ad valorem stamp duty still applies, from a fixed HK$100 for prices up to HK$4 million to 4.25% above HK$20 million, under rates effective February 26, 2025 (Brief Guide).

Hong Kong-dollar mortgage. Repaying a foreign-currency loan can create US currency gain (IRC §988), while a loss on a personal-residence loan is generally nondeductible. The risk is small in Hong Kong, where the currency is linked to the dollar within HK$7.75–7.85 (HKMA, How does the LERS work?).

Rental income. Hong Kong property tax is 15% of net assessable value, which is rent minus rates paid by the owner, minus a flat 20% allowance for repairs and outgoings; actual expenses are not deductible, and mortgage interest is deductible only under personal assessment (PAM 54; Brief Guide). In the US you report rent on Schedule E, deduct actual expenses and depreciation, and may credit Hong Kong property tax.

Employment, equity compensation and remote work for a US employer

US source. Pay for services performed outside the US is foreign-source (IRC §862(a)(3)), even from a US company.

Remote work for a US employer. A contract with a US employer, negotiated and enforceable abroad and paid outside Hong Kong, may be a non-Hong Kong employment, taxable only for days worked in Hong Kong (DIPN 10). Living in Hong Kong full time, you cannot rely on the 60-day "visits" rule. The IRD may look beyond the paperwork.

Withholding. Hong Kong collects salaries tax by assessment and provisional tax rather than payroll withholding (PAM 39). A US employer may keep withholding US tax unless you file Form 673 or adjust withholding; FICA follows the social security rules above.

RSUs and options. Hong Kong taxes option gains on exercise, assignment or release (IRO s.9(1)(d)), and employment-conditioned share awards generally on vesting, apportioned by Hong Kong days for a non-Hong Kong employment; on permanent departure you may elect deemed exercise or vesting (DIPN 38, rev. March 2008). US sourcing generally follows workdays over the relevant period (Treas. Reg. §1.861-4(b)(2)(ii)). The different timing makes credit matching delicate.

Leaving Hong Kong

Hong Kong itself has no exit tax, but a green card holder who later gives up status can still face US expatriation rules — see our guide on US Exit Tax §877A for the US side.

No exit tax. Hong Kong has no tax on unrealized gains when you leave. Departure is handled through tax clearance:

  • You: if you are chargeable and will leave Hong Kong for more than one month, you must notify the IRD in writing at least one month before departure (IRO s.51(7)), unless your work requires frequent travel.
  • Your employer: it must file Form IR56G at least one month before your expected departure and generally may not pay you any money or money's worth for one month after that notice without the Commissioner's written consent (IRO s.52(6)–(7), as described in IRD guidance on employer obligations).
  • Share awards: consider the departure election in DIPN 38.
  • MPF: decide whether to use the one-time permanent-departure withdrawal.

US side. Nothing changes for citizens. Green card holders giving up status may face expatriation rules (IRC §877A).

Mistakes Americans commonly make in Hong Kong

  1. Assuming no Hong Kong tax means no US tax on investment income and gains.
  2. Choosing the foreign tax credit by habit. With Hong Kong's low rates, the FEIE and the high Hong Kong housing limit often matter more.
  3. Putting Hong Kong tax on the wrong Form 1116. Tax for a year of assessment generally accrues on March 31.
  4. Overlooking MPF reporting, including FBAR, Form 8938 and possible trust or PFIC filings.
  5. Buying Hong Kong unit trusts or ETFs without considering PFIC rules.
  6. Expecting a totalization exemption. None exists.
  7. Leaving without tax clearance, which can delay your final pay.
  8. Treating a Hong Kong permanent identity card as a tax status.

Checklist

Before moving: decide between FEIE (with housing exclusion) and credit; ask your employer whether you will be on a Hong Kong or overseas contract and whether FICA continues; check whether you qualify for an MPF exemption.

First 90 days: keep a day-count log for Hong Kong and travel; record your housing costs; start an FBAR/8938 log for new bank and MPF accounts.

Every year: file the Hong Kong return when issued (generally due within a month of early May); pay provisional tax in January and April; file the US return (June 15 automatic, October 15 with Form 4868), FBAR and any Forms 8938, 3520, 8621 or 5471; match Hong Kong tax to the right US year.

Before leaving: notify the IRD a month ahead; make sure your employer files Form IR56G; consider the DIPN 38 election; decide on MPF withdrawal.

Frequently asked questions

Do I have to file US taxes if I live in Hong Kong?

Generally yes, if worldwide income exceeds your filing threshold or you have $400 or more of self-employment earnings.

Is there a tax treaty between the US and Hong Kong?

No. Relief comes only from the US foreign tax credit and the Foreign Earned Income Exclusion.

Does Hong Kong tax my US investment income?

Generally no. Hong Kong's salaries, profits and property taxes do not reach an individual's foreign investment income, though the US does.

Do I pay Social Security in Hong Kong and the US?

Possibly, if an American employer keeps you on US payroll; there is no totalization agreement.

Is my MPF account taxable in the US?

The law is unsettled. Practitioners differ on trust treatment, current taxation of employer contributions and PFIC status.

Does the 60-day rule mean I pay no Hong Kong tax?

Only for visits of 60 days or fewer in a year, under the right kind of employment.

When to hire a professional

  • Choosing FEIE, housing exclusion or credit, or matching Hong Kong's tax year: a US CPA or enrolled agent who works with Hong Kong clients.
  • MPF, ORSO or Hong Kong funds: a US preparer experienced with foreign trust and Form 8621 filings.
  • Remote work, split contracts or share awards: a Hong Kong tax adviser familiar with DIPN 10 and DIPN 38, plus your employer's payroll team.
  • A Hong Kong company: a US international tax adviser (classification, CFC, NCTI) and a Hong Kong certified public accountant.
  • Property trading: a Hong Kong solicitor and tax adviser.

Sources

Source URL Used for Date of page
IRS, US income tax treaties A to Z https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z Confirms Hong Kong has no US income tax treaty Reviewed Jan. 3, 2026
SSA, International Agreements (overview) https://www.ssa.gov/international/agreement_descriptions.html Confirms Hong Kong is not on the totalization-agreement country list Accessed Oct. 11, 2026
IRS, Totalization Agreements https://www.irs.gov/government-entities/federal-state-local-governments/totalization-agreements Dual Social Security liability when an American employer sends staff to a non-agreement country Accessed Oct. 11, 2026
IRS, filing requirements for US citizens and residents abroad https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-residents-abroad-filing-requirements Who must file, and that excluded FEIE income still counts toward the threshold Reviewed Sept. 28, 2026
IRS, Where and When to File and Pay (abroad) https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad-where-and-when-to-file-and-pay April 15 / June 15 / October 15 deadlines and the Form 4868 extension Reviewed Sept. 28, 2026
IRS, 2026 tax year inflation adjustments https://www.irs.gov/newsroom/irs-releases-tax-inflation-adjustments-for-tax-year-2026-including-amendments-from-the-one-big-beautiful-bill 2026 standard deduction and FEIE ($132,900) amounts Accessed Oct. 11, 2026
IRS Notice 2026-25, foreign housing cost limits https://www.irs.gov/pub/irs-drop/n-26-25.pdf 2026 housing exclusion base, general cap and the Hong Kong-specific limit Accessed Oct. 11, 2026
IRS, Form 8938 instructions https://www.irs.gov/instructions/i8938 Form 8938 thresholds for taxpayers abroad, and that a foreign pension plan is reportable as one asset Rev. 11/2021
FinCEN, FBAR due-date clarification notice https://www.fincen.gov/system/files/shared/FBAR_Due_Date_Clarification_PD02-02-2018.pdf FBAR due date and the automatic extension to Oct. 15 Accessed Oct. 11, 2026
Treas. Reg. §1.905-1 (Cornell LII) https://www.law.cornell.edu/cfr/text/26/1.905-1 Foreign tax accrual timing, including the March 31 fiscal-year example Accessed Oct. 11, 2026
Treas. Reg. §301.7701-2, business entities https://www.ecfr.gov/current/title-26/part-301/section-301.7701-2 Hong Kong Public Limited Company on the US per se corporation list eCFR, Oct. 7, 2026
IRD, DIPN 10, salaries tax source https://www.ird.gov.hk/eng/pdf/dipn10.pdf Hong Kong vs. non-Hong Kong employment tests, and the 60-day visits rule Rev. June 2007
IRD, DIPN 21, profits tax source https://www.ird.gov.hk/eng/pdf/dipn21.pdf Profits tax source basis and exclusion of capital-asset gains Rev. July 2012
IRD, DIPN 23, Mandatory Provident Fund https://www.ird.gov.hk/eng/pdf/dipn23.pdf MPF contribution deduction cap and MPF exemptions for overseas entrants Rev. May 2019
IRD, DIPN 38, share-based benefits https://www.ird.gov.hk/eng/pdf/dipn38.pdf Taxation of RSUs and options on vesting/exercise, and the departure election Rev. March 2008
IRD, PAM 39(e), salaries tax leaflet https://www.ird.gov.hk/eng/pdf/pam39e.pdf Progressive and standard salaries tax rates, assessment and provisional tax May 2026
IRD, PAM 54(e), property tax leaflet https://www.ird.gov.hk/eng/pdf/pam54e.pdf Property tax rate, the 20% allowance, and the return-notification deadline Nov. 2022
IRD, A Brief Guide to Taxes 2025–2026 https://www.ird.gov.hk/eng/pdf/2026/BriefGuide20252026.pdf Overall tax structure, personal assessment, profits tax rates, stamp duty rates Oct. 2025
IRD, 2026–27 Budget – Tax Measures https://www.ird.gov.hk/eng/faq/budget2026_27.htm 2026/27 allowance increases and the one-off tax reduction Accessed Oct. 11, 2026
IRD, employer obligations on departing employees https://www.ird.gov.hk/eng/pdf/2023/oblig.pdf Form IR56G filing and the payment-hold period before departure 2023
IRD, AEOI pamphlet https://www.ird.gov.hk/eng/pdf/2016/aeoi_pam3.pdf CRS due-diligence start and first exchange dates Accessed Oct. 11, 2026
IRD, cancellation of demand-side stamp duties https://www.ird.gov.hk/eng/ppr/archives/24022808.htm Abolition of SSD, BSD and NRSD from Feb. 28, 2024 Feb. 28, 2024
Hong Kong Government, FATCA IGA press release https://www.info.gov.hk/gia/general/201411/13/P201411130432.htm Date the Hong Kong–US Model 2 FATCA agreement was signed Nov. 13, 2014
MPFA, mandatory contributions https://www.mpfa.org.hk/en/mpf-system/mandatory-contributions/employees MPF contribution rates and the relevant-income floor and cap Accessed Oct. 11, 2026
MPFA, press release on permanent-departure withdrawals https://mpfa.org.hk/en/info-centre/press-releases/202106005 One-time nature of the permanent-departure MPF withdrawal June 16, 2021
HKMA, How does the LERS work? https://www.hkma.gov.hk/eng/key-functions/money/linked-exchange-rate-system/how-does-the-lers-work/ Hong Kong dollar's convertibility range against the US dollar Accessed Oct. 11, 2026
Mayer Brown, end of the US shipping tax exemption for Hong Kong https://www.mayerbrown.com/en/insights/publications/2020/08/the-end-of-the-us-shipping-tax-exemption-for-hong-kong 1989 shipping-income exchange of notes and its 2020 termination notice Aug. 27, 2020
China Briefing, filing individual tax returns in Hong Kong https://www.china-briefing.com/news/filing-individual-tax-return-in-hong-kong-a-complete-guide/ BIR60 issue timing and the e-filing extension Accessed Oct. 11, 2026
DLA Piper, IRS notices on OBBBA §951A (NCTI) https://www.dlapiper.com/insights/publications/2025/12/irs-issues-notice-2025-75-notice-2025-7-notice-2025-78 GILTI renamed net CFC tested income (NCTI) and removal of the tangible-asset carve-out Dec. 10, 2025

A note on scope: this guide is general information, not tax or legal advice. Which exclusion or credit strategy fits you, whether the MPF triggers trust or PFIC reporting in your case, and how a Hong Kong company is classified all depend on your own facts. Get advice from a US preparer experienced with Forms 1116, 8621, 3520 and 8938 and a Hong Kong certified public accountant before you rely on anything in this guide.

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