Can US persons buy Hong Kong insurance?

Sometimes, but acceptance is restricted and US tax obligations can apply even while living abroad. Hong Kong Insurance Connect provides information and referrals to a licensed Hong Kong broker; check with the broker before booking a trip. We do not recommend or arrange insurance.

Checked on 11 Oct 2026 · General information, not tax or legal advice.

Who counts as a US person?

US citizenship and US tax residence matter, not just your passport or current address. A green card or substantial presence can create US tax residence; exceptions require individual review. Tell the broker all citizenships, residences and tax statuses, including dual nationality. Moving to Hong Kong does not itself end US obligations. [U1, U8]

Why might an insurer refuse my application?

US-person exclusions are a practical barrier. Bowtie’s public residency article describes an exclusion, and HSBC Life’s Swift Save brochure requires applicants not to be US persons for US tax purposes. These are dated examples, not a current acceptance list for all products. Many insurers may decline this business; these sources cannot quantify how many. Check with the broker and obtain current insurer confirmation for the exact plan. FATCA forms on an insurer’s website do not prove that it accepts new US-person applications. [I1, I2]

Do FATCA, Form 8938 and FBAR apply?

Cash-value foreign insurance can fall within both Form 8938 and FBAR reporting. Form 8938 is filed with the IRS tax return; FBAR is filed separately with FinCEN. The FBAR threshold is aggregate foreign accounts exceeding USD 10,000 at any time. For unmarried US-resident filers, Form 8938 thresholds are over USD 50,000 at year end or USD 75,000 at any time; joint filing and living abroad have different thresholds. These are aggregate values, not premium limits. FATCA reporting by an insurer does not discharge your personal filings. [U2]

Could an investment-linked policy involve PFIC rules?

Ask a US tax adviser to examine the contract and underlying funds. Form 8621 concerns direct or indirect PFIC shareholders; investment-linked structures can raise classification questions. Neither the label “insurance” nor Hong Kong regulation establishes US treatment, and not every Hong Kong policy is a PFIC. Obtain a policy-specific review before committing, including whether fund information needed for filings is available. [U3]

Does the policy qualify under IRC 7702?

US life-insurance treatment requires applicable-law life insurance plus the cash-value accumulation test or the guideline-premium and cash-value-corridor requirements. Hong Kong approval alone does not certify those tests. Failure can bring annual income inclusion under section 7702(g). Request technical evidence for a US adviser; we have not verified qualification of any individual Hong Kong contract. [U4]

Is there a 1% premium tax and Form 720 filing?

Foreign-issued life, sickness, accident insurance and annuity premiums can attract federal excise tax at 1%. Casualty insurance has a different rate. US-citizen/resident coverage, statutory scope and any exemption must be checked; “offshore” does not itself mean exempt. The current Form 720 reports foreign-insurance premiums for the quarter under IRS No. 30; the premium payer generally files. Ask your adviser who will file and pay before the first premium and each renewal. Do not assume the insurer handles it. [U5, U6, U7]

Which state rules should I check?

New York DFS warns against unauthorised sales within New York, including falsely recording an overseas sale. Its circular distinguishes genuinely out-of-state activities; it does not approve every offshore purchase. Your state’s rules and the location of solicitation, application and delivery need separate review. Check with the broker and your state regulator before taking part in a sales discussion from the US. [S1]

What else should I read before enquiring?

Use the United States country guide for travel, payment and claims questions, and the UK guide if moving there. Read how to verify the broker and the fulfillment ratios hub; historical ratios do not establish tax treatment or future returns. Send a general enquiry stating your US status and residence. The licensed broker handles eligibility, advice and arrangement; a US adviser handles your tax review.

What do US buyers commonly ask?

I have two passports. Can I leave out the American one?

No. Disclose all citizenships and US tax status; another passport does not remove US obligations. [U1]

I live in Hong Kong. Am I still affected?

US citizens can still have US tax obligations abroad. Ask your adviser to review your actual status. [U1]

Will the broker find an insurer that accepts me?

Acceptance is not promised. Check with the broker for current written confirmation on the exact product. [I1, I2]

Is FATCA the same thing as my FBAR?

No. Insurer reporting, your Form 8938 and your FBAR are separate obligations. [U2]

Is every Hong Kong savings policy a PFIC?

No blanket conclusion is supported. Have the contract and any underlying funds reviewed individually. [U3]

Can I assume the policy passes 7702?

No. Ask for technical evidence that your US adviser can assess against the US qualification tests. [U4]

Will the insurer pay my 1% tax for me?

Do not assume so. Confirm liability, exemptions and who files Form 720 before paying premiums. [U5, U6, U7]

Where are the sources?