I am a Swiss citizen who now lives in the U.S. since four years. Before moving to the U.S., I worked in Switzerland and contributed to a pension. When I moved to the U.S. I did not take the pension money -- it is still in an account at BEKB. Now I am a U.S. resident and taxpayer, and I would like to know whether the earnings of my Swiss retirement account are taxable by the American IRS as they accrue -- in other words, before I retire and begin to withdraw them. Again, by way of summary:

(1) Swiss citizen
(2) Swiss retirement pension
(3) Pension contributions earned solely through Swiss job by Swiss resident
(3) Account holder is now a U.S. resident and taxpayer
(4) Account holder is not yet retired
(5) Account holder is not taking any distributions

Are the internal earnings of the pension fund taxable in the U.S.? I have done some research on the internet, but the IRS website is hard to understand. Thank you!

Yes. Both contributions to a Swiss pension from your employer, and any gains earned by the account are taxable income. Additionally, you will need to declare the account's highest value during the year on the FBAR that you are required to file.

I strongly suggest contacting an accountant with expertise in CH<->US tax matters. There is a double taxation treaty that will likely ease your tax burden.

First of all, for clarity: the contributions and appreciation /prior/ to when you became a US resident are not taxable by the US. (I hope that is obvious, but if not please reply).

AFTER you became a US resident: Most foreign (non-U.S.) pensions have not bothered to qualify as tax-exempt with the IRS, so "yes" the earnings are taxable by the IRS if (and /only/ if) you have the right to withdraw the funds. However, if you cannot withdraw the funds (for example, "not until age xxx"), then "no" since it the account is not under your control.

P.S. As a practical matter, the IRS has no possible way of finding your Swiss pension account.