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Mohsen Ghazi is a Partner at McDermott Will & Emery LLP.
Steven Hadjilogiou is a Partner at McDermott Will & Emery LLP.
While much attention has been paid to the estimated USD 100 trillion inter-generational wealth transfer, comparatively less focus has been given to the ongoing ‘Great Wealth Migration’. According to the Henley Global Mobility Report 2025, approximately 134,000 millionaires relocated internationally in 2024 alone, driven by geopolitical instability, inflation pressures, and evolving tax environments. This migration is expected to accelerate further into 2025, with 142,000 high-net-worth individuals expected to seek new horizons, potentially influenced by the Trump Administration’s proposal for a USD 5 million ‘Gold Card’ residency visa. If enacted, this visa would uniquely exempt holders from US taxation on foreign-source income and offers permanent residency with a pathway to citizenship — a potentially highly attractive incentive among global residency programs for a country that already has 11 of the Top 50 wealthiest cities in the world.
The global tax landscape differs dramatically by jurisdiction. Countries such as Canada, the UK, and France are tightening wealth and inheritance taxation, while others, including Italy, Portugal, Spain, Singapore, Switzerland, and the UAE are actively attracting affluent families through favorable tax frameworks and tailored family office incentives. Heightened trade tensions, government austerity measures, and ambitious budget-balancing initiatives further amplify risks for wealthy individuals and their portfolios, prompting geographic diversification as a risk mitigation tool.
Historically, the US practice of taxing residents on worldwide income has deterred many wealthy foreign individuals from relocating. The proposed Gold Card visa would dramatically reverse this dynamic by exempting foreign-source income from US taxation — a major policy shift from current US immigration programs and competitive with global residency alternatives. Of course, the Gold Card is merely speculative at this moment.
Under current law, there are many pre-immigration tax planning techniques that can significantly reduce the US income tax and estate tax liabilities that could apply after US residency is established. Owners of non-US businesses must carefully navigate complexities such as Controlled Foreign Corporation (CFC) and Passive Foreign Investment Company (PFIC) rules, which can lead to unexpected tax liabilities, even when cash has not been received. Strategic pre-immigration restructuring, including reorganizing holding companies, trusts, and disposing of investments can be important tools in managing these risks.
Families relocating to the USA must account for significant succession implications. For example, the children of US residents automatically acquire US citizenship when they are born in the country, which can expose global family assets to US estate and gift taxes of up to 40%. Additionally, anti-deferral rules (the CFC and PFIC rules noted above) further complicate wealth transfers, potentially triggering immediate taxes and extensive reporting burdens. Engaging in pre-immigration restructuring is important to facilitate seamless inter-generational wealth transfers and minimize tax exposure.
US nationals relocating internationally must also adopt thoughtful pre-departure strategies. Expatriation planning can mitigate significant exit taxes triggered upon relinquishing US citizenship or long-term residency. Structuring gifts and irrevocable trusts prior to becoming domiciled abroad helps protect global assets from US estate and gift taxation.
Before becoming US residents, individuals should evaluate their portfolios and consider realizing gains, thereby mitigating US tax exposure with respect to appreciation. Further, accelerating income recognition pre-immigration and deferring deductible expenses until after establishing US residency can optimize tax efficiency.
Once residency is established, investors can leverage the following targeted US tax incentives to maximize returns:
Qualified Opportunity Zones (QOZ): Investors can defer existing capital gains taxes until 2026, with permanent exclusion of subsequent gains if investments are held for at least 10 years.
Qualified Small Business Stock (QSBS): Allows exclusion of up to USD 10 million (or 10 times the investment basis) in federal capital gains taxes for qualified investments in early-stage US corporations.
Puerto Rico Tax Planning: Relocating to US territories such as Puerto Rico can significantly reduce capital gains and income taxes for qualified residents but also comes with heightened compliance and complexity. With proper planning, relocation can amplify wealth preservation and growth.
The proposed Gold Card residency underscores intensifying global competition for high-net-worth families. While Dubai and Singapore remain attractive destinations, potential US tax incentives could significantly redirect global wealth flows if enacted. Similarly, growing numbers of US nationals pursuing international diversification reflect increasing domestic uncertainties, emphasizing the importance of proactive, sophisticated cross-border wealth planning.
Given the complexity and dynamic nature of these issues, engaging specialized cross-border tax counsel can dramatically impact the accumulation of wealth. Effective pre-migration strategies and targeted tax-advantaged investments are important not only for wealth preservation, but also for ensuring financial resilience amid shifting global dynamics.
Henley & Partners assists international clients in obtaining residence and citizenship under the respective programs. Contact us to arrange an initial private consultation.
