Jacob Salama · International Tax Lawyer · Colegiado nº 11.294 ICAMálaga
24%
Beckham Law flat rate on employment income
6 yrs
Duration of Beckham Law regime
7.65% top rate
Wisconsin state income tax
Wisconsin's 7.65% top income tax rate is significant. Epic Systems (healthcare IT, based in Verona) has generated a large cohort of mid-career professionals with deferred equity. Madison's university ecosystem and Milwaukee's industrial base are also notable sources of expat candidates. Jacob Salama advises professionals and business owners from Wisconsin who are relocating to Spain on the full spectrum of US-Spain tax compliance: pre-departure asset planning, Beckham Law applications, FATCA, FBAR and Modelo 720 obligations, and ongoing dual-filing coordination. Whether you are based in Milwaukee, Madison, Green Bay, Kenosha, the planning principles are consistent — but the details depend on your specific circumstances and asset mix.
The 1990 US-Spain DTA (as amended by the 2013 Protocol) governs the allocation of taxing rights between the two countries. For US citizens — unlike nationals of any other country — the treaty's Saving Clause (Article 1(4)) preserves the United States' right to tax its citizens on worldwide income regardless of Spanish residence. A US national from Wisconsin who becomes a Spanish tax resident remains fully subject to US federal income tax. The foreign tax credit mechanism under Article 24 of the DTA is the primary tool for avoiding economic double taxation, but its application requires careful sequencing with Spanish IRPF or Beckham Law calculations.
The Beckham Law (Article 93 LIRPF), as expanded by Spain's 2022 Startup Law, allows qualifying individuals becoming Spanish tax residents for the first time to be taxed at a flat 24% on Spanish-source employment income up to €600,000, rather than the progressive general IRPF rate (up to 47%). Most foreign-source income is excluded from Spanish IRPF during the Beckham period. For professionals from Wisconsin earning in dollars from a US employer, this means: the Spanish salary is taxed at 24%, while dividends, rental income, and capital gains from US assets may be entirely outside Spanish IRPF. The application is made via Modelo 149 within six months of Spanish social security registration.
US nationals who move from Wisconsin to Spain and become Spanish tax residents face three overlapping foreign asset reporting obligations. First, the FinCEN 114 (FBAR) requires disclosure of all foreign financial accounts exceeding $10,000 in aggregate at any point during the calendar year. Second, FATCA (Form 8938) requires separate disclosure of foreign financial assets above the applicable threshold. Third, Modelo 720 requires Spanish tax residents to declare foreign bank accounts, securities and real estate above €50,000 per category. Jacob coordinates all three streams to ensure full compliance and to identify voluntary disclosure opportunities where historical non-compliance exists.
Wisconsin state income tax (7.65% top rate) ceases to apply once you properly establish non-residency in Wisconsin. The key steps involve: (1) establishing a new domicile in Spain (or another state before Spain); (2) filing a part-year resident return for the year of departure; (3) ensuring you do not maintain a permanent place of abode in Wisconsin after departure; and (4) spending fewer than the statutory number of days in Wisconsin in future years. The exact rules vary by state and some states (notably California, New York, and New Jersey) are particularly aggressive in asserting continued residency. Jacob advises on the state-level exit process as part of the integrated US-Spain move planning.
Wisconsin's top income tax rate is 7.65% on income above $315,000 for married filers. Wisconsin's Department of Revenue applies standard domicile and presence tests for residency. Wisconsin is not aggressive in challenging post-departure domicile changes, though maintaining a Wisconsin property and spending significant time there risks triggering Wisconsin statutory residency.
Wisconsin's economy includes manufacturing (Harley-Davidson in Milwaukee, Oshkosh Corporation, Briggs & Stratton, paper and printing), financial services (Northwestern Mutual, Baird, Marshall & Ilsley), healthcare (Froedtert Health, UW Health, Aurora Health Care), agriculture (dairy — Wisconsin is America's Dairyland), food processing (Kraft Heinz operations), and a growing technology sector in Madison around the University of Wisconsin ecosystem. Expats from Wisconsin moving to Spain include financial services executives, manufacturing professionals, healthcare administrators, and agribusiness owners.
For professionals relocating from Wisconsin to Spain, the Beckham Law (Article 93 LIRPF) — a flat 24% rate on Spanish-source employment income up to €600,000 for the first six years — can represent a substantial reduction in effective tax. Combined federal and Wisconsin rates can approach ~44.65%, making the Beckham Law's 24% flat rate particularly attractive.
| Scenario | Top Effective Rate | Approx. Tax on $180k Income |
|---|---|---|
| US — Federal (37%) + WI (7.65%) | ~44.65% | ~$80,370 |
| Spain — Beckham Law (employment income) | 24% flat | ~€43,200 |
| Spain — Standard IRPF (no Beckham) | Up to 47% | ~€68,400+ |
Wisconsin does not have a blanket retirement income exemption but allows deductions for certain qualifying pension income. Social Security is not taxed by Wisconsin. Military retirement pay is exempt. Private 401(k) and IRA income is taxable at full Wisconsin rates. Moving to Spain subjects these income streams to Spanish IRPF.
Under the US-Spain Double Taxation Agreement, private pension and 401(k) distributions are taxable in Spain once you are a Spanish tax resident. The US may withhold at source, but this is creditable against Spanish IRPF. The Roth IRA creates a double-taxation risk — Spain does not recognise its US tax-exempt status. Pre-departure drawdown planning while still a Wisconsin resident (paying only federal tax, with no Wisconsin state tax on retirement income in many cases) can significantly reduce lifetime tax costs.
Key planning point for Wisconsin expats: Northwestern Mutual and Baird employees from Milwaukee are typically in financial services with significant deferred compensation and partnership income interests. For Wisconsin-based financial services professionals considering a Spain relocation, the Beckham Law's foreign income exclusion for the first six years can be especially valuable: investment management income from US clients that is US-source income remains outside Spanish IRPF during the Beckham period.
Spanish wealth tax (Impuesto sobre el Patrimonio) applies to tax residents on their worldwide assets exceeding the personal allowance (€700,000 for residents, plus an additional €300,000 for the primary residence). For expats from Wisconsin with significant investment portfolios, property, or business interests, wealth tax is an important planning consideration. The rates range from 0.2% on the first tier to 3.5% on the highest. The choice of Spanish region of residence significantly affects wealth tax exposure: residents of Madrid enjoy a 100% bonificación (effectively zero wealth tax), while Andalucía has a 99% bonificación. In contrast, Cataluña and Comunitat Valenciana apply wealth tax in full. For high-net-worth individuals from Wisconsin with substantial assets, the choice of Spanish region of residence can result in wealth tax differences of tens of thousands of euros per year.
Under the Beckham Law special regime (Article 93 LIRPF), Spanish wealth tax applies only to Spanish-located assets — not worldwide assets — for the duration of the regime. This is an additional major advantage of the Beckham Law for wealthy expats from Wisconsin: for the first six years of Spanish residence, your US brokerage portfolio, IRA, 401(k), US real estate, and other US-located assets are entirely outside the Spanish wealth tax base. Once the Beckham period ends and you transition to the standard IRPF regime, worldwide wealth becomes assessable.
Many professionals from Milwaukee and Madison in the financial services and manufacturing sector are exploring remote work arrangements that allow them to live in Spain while continuing to work for their WI-based employer. This arrangement raises specific tax and compliance questions that must be addressed before the move.
A well-structured pre-departure process can significantly reduce your total tax burden and avoid costly compliance failures. Key steps for Wisconsin residents preparing to move to Spain include:
Why specialist advice matters: Moving from Wisconsin to Spain involves simultaneous US federal, WI state, and Spanish tax obligations. General advisors typically lack the cross-border expertise to optimise all three at once. Jacob Salama advises Wisconsin nationals moving to Spain on the complete picture — from pre-departure planning through the first Spanish IRPF return and beyond.
Moving from Wisconsin to Spain involves complex US-Spain tax interactions that general advisors miss. Jacob handles every private client case personally.
The content on this page is for general informational and educational purposes only. It does not constitute legal or tax advice and does not create a lawyer-client relationship. Tax laws change frequently and their application depends on individual circumstances. Always obtain specific professional advice before taking any action. Jacob Salama — Salama Legal SLP — is a registered Spanish lawyer (Colegiado nº 11.294, ICAMálaga) and is not authorised to provide US or UK legal advice.