International Tax Planning

Your exposure is decided less by where you move than by what you already are. A US person is taxed on worldwide income wherever they live. A Canadian, British or European family is taxed by residence, and can genuinely leave. Almost every question below splits along that line.

I am a licensed real-estate and investment-migration professional, and the part I work on is timing — which decisions carry a date, and which of those dates fall before the move. That is the role I play across the rest of the private client advisory work.

If you hold a US passport, one fact sits above everything else: the United States taxes its citizens on worldwide income wherever they live. A second passport does not change a federal filing, and neither does a foreign address or a Caribbean structure.

The Foreign Earned Income Exclusion shelters US $132,900 for 2026, and only earned income qualifies — not capital gains, dividends, interest or rent. For a family living on a portfolio rather than a paycheck that is close to irrelevant, and none of the five Eastern Caribbean citizenship programs holds a US income tax treaty to fall back on. I treat second citizenship for Americans as insurance rather than a tax play.

If the tax bill is genuinely the objective, the shortlist is short. Puerto Rico’s Act 60 is where most American families end up, because it changes the math inside the US system instead of around it, with no expatriation; families consolidating substantial mobile wealth sometimes weigh Anguilla’s flat tax instead. I treat renouncing US citizenship as the last step, taken rarely and never first.

For non-Americans the arithmetic differs in kind. Canada, the United Kingdom and most of Europe tax by residence, so genuinely leaving ends the claim, eventually and at a price on the way out.

This is the most expensive mistake I see, and it is not close. Almost every lever worth pulling has a date attached, and most of those dates fall before the move. Once the departure date fixes, the valuation date fixes with it.

I know this from my own file. I flew out of Canada in 2020 and was taxed as though I had sold nearly everything I owned in 2021, because the departure date runs on the latest of three dates, and the flight is only one of them. By the time my accountant walked me through the deemed-disposition math, most of the moves that would have shrunk the number had expired. I wrote up what the departure tax actually cost me and the seven levers that genuinely move it, because the gap between a six-figure bill and a five-figure one is decided months before anyone boards a plane.

Most of the money is lost on exit, and the trigger is a question of fact that no boarding pass settles, so how the CRA decides you have left and the Form NR73 trap are worth reading before the move, not after.

So the sequence I run is boring and fixed: answer the day-count question honestly, choose the tax-residency base around that answer, plan the exit in parallel with your own counsel, settle the ownership structure, and only then layer the passport on. The real estate frequently decides the tax plan instead of following it, which is why title on a citizenship by investment purchase gets settled before contracts are signed.

Citizenship, residency and tax residency get used interchangeably and mean three different things. Tax residency is the jurisdiction actually entitled to tax you, decided by presence and center of life rather than by what sits in your safe. Caribbean citizenship carries no residency requirement, so on its own it creates tax residency nowhere.

Day counts are the floor. Puerto Rico’s Act 60 runs on the familiar 183 days. Anguilla’s High Value Resident program asks 45 days a year on-island and the Cayman Islands residency certificate asks 30. I put the day-count question before the price question, because presence eliminates more shortlists than cost ever does.

Above the floor sits the harder test: where the center of your life is. Under the Common Reporting Standard, accounts are reported to the jurisdiction where you claim tax residency, so a certificate with no days and no home behind it reads as an audit flag. Nor is the region uniformly tax-free: of the five citizenship programs, only St. Kitts and Nevis and Antigua and Barbuda levy no personal income tax on residents.

Nobody on my side of the table takes a filing position. Returns, exit-tax modeling and treaty readings belong to your own cross-border tax counsel and CPA — and if you do not have one who does this daily, finding one is the first thing my team and I will tell you to do. What we do is define the problem before it reaches them: the day counts, the dates, the title, the order things happen in, set out clearly enough to be solved once.

Where the requirement runs past coordination — structuring that has to be executed, or a family-governance framework — I introduce a dedicated specialist private-capital practice and stay on the real-estate and citizenship side of the file myself. My team and I do not take the tax mandate. The conversation that has to happen early is the one about dates, while the departure date, the closing date and the filing year can all still be moved.