Your own LLC or S-corp
Owner-employees are the case we know from the inside: salary structure, substance and the telework route, reviewed before you commit to the move.
US citizens & green-card holders
The US side: the part nobody else models
As a US citizen or green-card holder you keep filing with the IRS under Beckham. The Spanish 24% is generally creditable against US tax (Foreign Tax Credit), the FEIE election changes the math, and FBAR/FATCA reporting continues. Which combination wins depends on both returns, get the two sides modelled together before you commit.
I am Javier López. Yolanda and I moved here from the United States and both hold the regime. What you read on this site comes from our own paperwork and from the rules, not from a sales script.
The US angle, handled natively
Most Spanish firms treat American clients as a footnote and point the IRS side back at your CPA. Our own taxes are US–Spain taxes, so the intake models both sides, and you get matched with professionals who work the US angle.
You still file with the IRS
Citizenship-based taxation does not pause under Beckham. FEIE vs. Foreign Tax Credit changes your real combined rate, both returns get modelled together, not just the Spanish one.
FBAR & FATCA stay
Beckham removes the Spanish Modelo 720, not the US reporting on your accounts. Knowing what disappears and what does not keeps you clean on both sides.
The treaty small print
Under the regime you usually cannot obtain a treaty residence certificate. For US-source income that changes withholding, it gets flagged before it costs you money.
From the posts: Beckham with a US LLC or S-corp →
FEIE vs. Foreign Tax Credit →
Nomad visa + your own US company →
US citizens on the digital nomad visa →
US LLC or S-corp: four setups compared →
Your 401(k), brokerage account and crypto under Beckham →
Spouse and children: when the whole family can hold the regime →
Spain + US, coordinated
Moving to Spain under the Beckham Law as a US citizen or green-card holder means two tax systems and two sets of filings. They are separate jobs, done by different people, and neither side files the other’s forms.
The Spanish side
A registered Spanish lawyer or tax advisor, or you with guided filing if your case is eligible
- Modelo 149 when you arrive: the application for the Beckham regime, within six months of your Spanish Social Security registration.
- Modelo 151 every year you stay in the regime: the Spanish annual return under Beckham.
The US side
A US tax preparer of your choice
- Form 1040 every year: US citizens and green-card holders keep filing with the IRS wherever they live.
- FBAR: the yearly report of your non-US bank and investment accounts when they pass the reporting threshold.
- Foreign Tax Credit or Foreign Earned Income Exclusion: the choice that sets how your Spanish tax is treated on the US return.
- Your LLC or S-corp, if you have one: its own US returns and elections.
We cover the Spanish side only: the free diagnosis, guided filing when your case qualifies, or a fixed quote from an independent registered professional we look for. We do not prepare US returns and have no arrangement with any US preparer. Both sides work from the same facts, so keep copies of what each one files and share them with the other.
Type of move: Owner-employee of my own US LLC / S-corp
Route: remote employment income paid by your own US company. It can fit the telework route, but when the employer is your own LLC or S-corp, AEAT looks hard at substance and salary structure. It is the exact setup we run ourselves, and the route worth reviewing with a professional before you file.
Your spouse and children under 25 can join the regime, each with their own Modelo 149 and their own conditions, including a rule that their combined taxable bases stay below yours every year. Worth knowing: family allowances only exist under the standard IRPF, so with several dependants the general regime can come out ahead at moderate incomes. Compare both side by side and choose the better one before anyone files.