United States
Up to $15M Tax-Free. If You Qualify.

The United States of America is a federal republic of approximately 335 million people spread across 50 states, the District of Columbia, and various territories. The largest city is New York City (8.3 million; metro 20 million). Other major cities: Los Angeles, Chicago, Houston, Phoenix, Dallas, Miami, San Francisco, Seattle, Boston, Austin. The US is the world's largest economy by nominal GDP ($28 trillion in 2025) and the leading global power in technology, finance, entertainment, and military capability.

The US federal income tax system is progressive at rates of 10–37% on ordinary income. Long-term capital gains are taxed at 0%, 15%, or 20% depending on income level. In addition, most states impose a state income tax (0% in Florida, Nevada, Texas, Washington, Wyoming, South Dakota, Alaska; up to 13.3% in California). The combined federal + state top rate can reach 50%+ in high-tax states like California and New York.

US citizenship-based taxation is the defining planning constraint: the US taxes its citizens and permanent residents (green card holders) on worldwide income regardless of where they live. A US citizen living in Dubai, Georgia, or the Cayman Islands owes US federal income tax on all worldwide income. This makes the US uniquely difficult as a jurisdiction for internationally mobile individuals who want to reduce their tax burden by relocating — they cannot.

For non-US persons moving to the US: US taxation begins on the first day of US resident status — there is no foreign income exemption equivalent to the UK's FIG regime or New Zealand's transitional exemption. The planning opportunity lies in the specific tax incentives within the US system, not in territorial treatment of foreign income.

Key US-specific tax benefits: QSBS exclusion (IRC §1202): up to $10 million in gain ($20M for married couples) on qualifying C-corporation startup stock held for 5+ years is completely excluded from federal capital gains tax. Primary residence exclusion (IRC §121): gains up to $250,000 ($500,000 married) on the sale of a primary residence are excluded from capital gains tax. Opportunity Zones (IRC §1400Z-2): capital gains invested in designated Opportunity Zone funds receive deferral and potential permanent exclusion. Stepped-up basis at death: assets inherited by US heirs receive a step-up in basis to market value at death — eliminating embedded capital gains on inherited assets.

2026 United States OBBBA correction: the One Big Beautiful Bill Act signed 4 July 2025 made the TCJA federal rate structure permanent, raised the estate/gift/GST exemption to $15M per person from 2026, expanded QSBS for stock issued after 4 July 2025, increased the SALT cap temporarily, and preserved the central structural issue: US citizens and green card holders are taxed on worldwide income regardless of residence. For DACH HNW clients, pre-immigration planning, PFIC avoidance, QSBS eligibility, state residency, and §877A expatriation exposure are the core issues.

• ›New York City is the argument for the United States that doesn't require elaboration, and yet it does. The Manhattan skyline from the Brooklyn Bridge at dusk — the most imitated image in architecture, still improbable even when you've seen it a hundred times. Central Park in October, the leaves turning, the runners and the chess players and the musicians and the wedding parties. The Met, MoMA, the Guggenheim, the Whitney, the Frick — a density of museum quality available on a single subway line that no other city in the world matches. The West Village and the Lower East Side and DUMBO and Williamsburg — the neighbourhoods that have no equivalent in any other city because they've been doing this — the layering of successive immigrant cultures, the churning of creativity and commerce — continuously and without interruption since the Dutch arrived in 1609.
• ›Miami is the city of the 2020s in a way that San Francisco was the city of the 2010s. The combination of zero state income tax, Latin American cultural energy, the beach, and a business community that has relocated from New York and California at high speed since 2020 has created something new: a financial and tech hub with Miami's weather and Miami's nightlife. Wynwood, Brickell, Coconut Grove — the neighbourhoods accumulate and the city doesn't stop changing.
• ›Austin in Texas is the other relocation story: tech industry anchor (Tesla, Apple, Google, Oracle all have major presences), zero state income tax, live music, the Colorado River, a cost of living that makes Silicon Valley look unreasonable by comparison. The city has grown 25% in population since 2015 and shows no signs of stopping.
• ›San Francisco and the Bay Area remains the global capital of technology — regardless of which companies have relocated, the density of capital, engineering talent, and startup infrastructure has no equivalent elsewhere on earth. The Pacific coast between San Francisco and Carmel. The Napa and Sonoma wine country. The Sierra Nevada and Yosemite, 4 hours by road from the city.

"America is a country that doesn't know where it's going but is determined to set a speed record getting there."

— Laurence J. Peter, The Peter Principle, 1969

"New York is not a city. It is a world."

— Jorge Luis Borges, from various interviews, 1980s

"The American West is the landscape of the unfulfilled promise, and it is the most beautiful landscape in the world."

— Joan Didion, from various essays, 1960s–1970s

The US tax landscape was reset on 4 July 2025 by the One Big Beautiful Bill Act (OBBBA). OBBBA made permanent most TCJA individual provisions that were scheduled to sunset on 31 December 2025 — the seven-bracket federal structure topping at 37%, the higher standard deduction ($16,100 single / $32,200 MFJ for 2026), and the 20% Qualified Business Income (QBI) deduction for pass-throughs. The federal estate, gift, and GST tax exemption is permanently raised to $15M per person ($30M per married couple) from 2026, indexed for inflation. The most material change for HNW founders and early investors is the expansion of the QSBS Section 1202 exclusion: for stock issued AFTER 4 July 2025, taxpayers exclude 50% of gain at 3 years held / 75% at 4 years / 100% at 5 years, with the per-issuer cap raised from $10M to $15M and the corporate gross-asset threshold raised from $50M to $75M. The SALT cap is raised to $40,000 for 2025–2029 (phased down above $500K MAGI; reverts to $10,000 from 2030). Federal income tax 2026: 10% / 12% / 22% / 24% / 32% / 35% / 37% (top bracket above $640,600 single / $768,600 MFJ). Long-term capital gains 0% / 15% / 20%, with a 3.8% Net Investment Income Tax above $200K/$250K MAGI (top federal CG rate 23.8%). Federal estate tax 40% above the $15M exemption. Corporate income tax 21% flat (permanent). The structural reality unchanged and critical: the US taxes its citizens and green card holders on WORLDWIDE income regardless of residence — unique among major jurisdictions. FEIE for 2026 is $132,900. Renunciation of US citizenship by a "covered expatriate" triggers the §877A mark-to-market deemed-sale regime on worldwide assets. State income tax adds 0%–14.3% on top of federal.

• ›OBBBA made TCJA brackets permanent — federal income tax 10% / 12% / 22% / 24% / 32% / 35% / 37% for 2026 — top 37% bracket starts at $640,600 single / $768,600 MFJ. Standard deduction permanently raised: $16,100 single / $32,200 MFJ / $24,150 HoH for 2026. Personal exemption permanently $0. QBI 20% pass-through deduction made permanent. Long-term capital gains 0% / 15% / 20% with NIIT 3.8% above $200K/$250K MAGI (top federal CG 23.8%).
• ›Federal estate, gift, and GST tax exemption permanently raised to $15M per person ($30M per couple) from 2026 — replaces the scheduled reversion to ~$7M; indexed for inflation from 2027. Estate tax rate remains 40% above the exemption. Annual gift exclusion $19,000 per recipient for 2026 ($194,000 to non-citizen spouse). For most HNW US clients, federal transfer tax planning is deprioritized — basis step-up at death and non-grantor trust strategies become more important.
• ›QSBS (Section 1202) substantially EXPANDED for stock issued after 4 July 2025 — tiered exclusion: 50% at 3 years held / 75% at 4 years / 100% at 5 years (was 100% only at 5 years). Per-issuer cap raised to $15M from $10M, OR 10× basis (whichever greater), indexed from 2027. Corporate gross-asset threshold raised to $75M from $50M, indexed from 2027. Stock issued ≤4 July 2025 continues under prior rules. Non-grantor trust "stacking" continues — multiple NGTs each get separate per-issuer caps. For founders and early investors in qualifying C-corps, this is the most valuable HNW provision in decades.
• ›SALT deduction cap raised to $40,000 for 2025–2029 — up from $10,000 under TCJA. Cap and phase-out increase 1% annually 2026–2029. Phased down for MAGI >$500K; eliminated (capped at $10K) for MAGI >$600K. Reverts to $10,000 from 2030 unless extended. Material for high-income residents of high-tax states (California, New York, New Jersey, Massachusetts).
• ›Citizenship-based taxation — US citizens and green card holders taxed on worldwide income regardless of residence — unique among major jurisdictions. Foreign Earned Income Exclusion $132,900 for 2026 (bona fide residence or physical presence test); excludes earned income only — investment income, capital gains, business profits remain US-taxable. Foreign Tax Credit available on foreign income taxes paid. Renunciation of US citizenship by a "covered expatriate" (net worth ≥$2M OR 5-year average tax ≥$206K OR compliance issues) triggers §877A mark-to-market deemed sale of worldwide assets at FMV with ~$890,000 exemption (2025; 2026 indexed). Recipients of gifts/bequests from covered expatriates may face up to 40% §2801 recipient tax.
• ›Corporate Income Tax 21% flat (permanent); BEAT 10.5% from 2026; GILTI 13.125%; bonus depreciation and §174 R&E expensing restored — federal corporate tax 21% (TCJA, made permanent under OBBBA). BEAT permanently set at 10.5% from 2026. GILTI effective rate adjusted to 13.125%. Bonus depreciation 100% permanent for property placed in service after 19 January 2025. Domestic R&E expenses fully deductible in year incurred (foreign R&E 15-year amortization). §163(j) interest limitation restored to 30% of EBITDA (more favorable than EBIT).
• ›No federal VAT; State income tax 0%–14.3%; ~65 income tax treaties; US does NOT participate in CRS — no federal value-added tax (sales tax administered at state level: 0%–10%+). State income tax: 0% (Alaska, Florida, Nevada, South Dakota, Tennessee, Texas, Wyoming, plus Washington capital gains only) up to California 13.3% + 1% mental health surtax above $1M = 14.3% effective top California rate. The US does NOT participate in OECD Common Reporting Standard — US uses bilateral FATCA. ~65 income tax treaties including Germany, Switzerland, UK, France; the US-UAE has NO income tax treaty.
• ›Strict reporting regime — FBAR, FATCA Form 8938, Form 5471, Form 8865, Form 3520 — US persons (citizens, green card holders, US tax residents) must file FBAR (FinCEN 114) if foreign accounts aggregate >$10,000 at any time; FATCA Form 8938 with thresholds $50K–$600K depending on filing status and residence; Form 5471 for CFC ownership; Form 8865 for foreign partnership interests; Form 3520 / 3520-A for foreign trusts and large foreign gifts (>$100K from individuals/estates). Penalties for non-filing severe ($10K+ per non-willful FBAR violation; up to 50% of account balance for willful). PFIC regime applies punitive treatment to foreign mutual funds, ETFs, and certain pooled investments held by US persons.

US tax residency for non-US-persons: the Substantial Presence Test — being present in the US for 31 days in the current year AND 183 days total over 3 years (counting all days in the current year, 1/3 of days in the prior year, 1/6 of days two years prior). Alternatively, holding a Green Card (permanent resident status) triggers worldwide taxation from the date of issue.

Cessation of US tax residency: Green card holders who surrender their green card and have been US residents for 8 of the last 15 years are subject to the expatriation tax (same rules as for citizens who renounce). US citizens who renounce citizenship face the expatriation tax — a deemed disposition of all worldwide assets at market value, triggering US tax on the unrealised gain.

The US has approximately 70 active DTAs — comprehensive but not the largest network globally. The network covers the UK, Germany, France, Netherlands, Switzerland, Japan, Australia, Canada, Ireland, and most OECD economies. Notable absences include Brazil, Argentina, and a number of Gulf states.

• ›The US-UK DTA (2001 Convention) is the most important bilateral instrument for the largest group of internationally mobile individuals in the US. It provides reduced withholding on UK-source dividends and interest for US residents, allocates pension taxing rights, and contains the standard savings clause preserving the US right to tax its own citizens.
• ›The US-Germany DTA governs German-source income for German nationals in the US. German dividends flowing to US residents benefit from treaty-reduced withholding. German statutory pension income paid to US residents is governed by the DTA pension article.
• ›The US-Switzerland DTA (1996 Convention, 2010 Protocol) is the foundational instrument for Swiss nationals and those with Swiss investment portfolios. The FATCA Model 2 IGA means Swiss banks report US-person accounts directly to the IRS.
• ›The US-Singapore DTA and US-Japan DTA are the most important Pacific instruments, reflecting the significant US professional and investment presence in Singapore and Japan.
• ›US citizens abroad: Even when living in a DTA country, US citizens cannot use the treaty to exempt themselves from US worldwide taxation. The savings clause in every US DTA preserves the US right to tax its own citizens regardless of where they live.

2026 treaty update: the United States has about 65 active income tax treaties, including Germany, the UK, Switzerland, France, Australia, Canada, Japan, China, and India. The treaty saving clause preserves US taxing rights over US citizens regardless of treaty residence. There is no US-UAE income tax treaty, no comprehensive US-Singapore income tax treaty, and no US-Hong Kong treaty.

For non-US persons moving to the United States, the primary planning imperative is not avoiding home-country tax after arrival — it is completing the home-country departure before US tax residency begins. Once you become a US tax resident, the US taxes you on worldwide income. Gains realised before that date are not subject to US tax. Gains realised after it are. The pre-immigration planning window is measured in months, not years.

For German nationals, the §6 AStG exit tax on shareholdings of 1% or more must be addressed before departure from Germany. The Germany-US DTA governs the bilateral relationship after arrival. For British nationals, the SRT exit date from UK residency must be established before US tax residency begins. The UK-US DTA governs the bilateral relationship.

Before you relocate, you need to understand what tax consequences arise in your current country of residence at the point of departure. These rules vary significantly by country and must be assessed individually — there is no universal answer.

Many countries impose an exit tax or deemed disposal charge when a tax resident leaves. This typically applies to unrealised capital gains on shares, business interests, real estate, or other assets — taxing you as if you had sold everything on the day you departed. The rules differ widely: some countries apply this to all assets above a threshold, others only to substantial shareholdings or business interests. Some have look-back periods that can catch you even after you have left.

The timing of your departure, the structure of your assets, and the sequence of any business disposals all have material consequences. In some cases, restructuring assets before departure — or deferring the move by a few months — can make a significant difference to the tax outcome.

• ›Germany. The §6 AStG exit tax on shareholdings of 1% or more applies at departure from German tax residency. This is entirely separate from the US pre-immigration planning — both must be completed before arriving in the US. German dividends paid to US residents benefit from reduced withholding under the Germany-US DTA. German statutory pension income paid to US residents is governed by the DTA.
• ›United Kingdom. SRT exit date from UK residency must be established before US tax residency begins. UK CGT on UK-sited assets at departure. The UK-US DTA governs the bilateral relationship. UK pension income paid to US residents is governed by the DTA — and is also subject to US worldwide taxation, with a Foreign Tax Credit for UK withholding.
• ›For US citizens leaving the United States. Green card holders who have been US residents for 8 of the last 15 years, and US citizens who renounce, are subject to the expatriation tax — a deemed disposition of all worldwide assets at market value, triggering US tax on all unrealised gains. This is an irrevocable and significant event that requires specialist advice well in advance.

The US LLC (Limited Liability Company) is one of the most widely used structures globally for internationally mobile non-US persons. For non-US persons, a US LLC with no US business activity and no US members is typically treated as a disregarded entity or partnership for US tax purposes — producing no US corporate income tax on non-US-source income. This makes the US LLC uniquely efficient for globally mobile entrepreneurs serving international clients.

QSBS planning: To benefit from the $10M QSBS exclusion, the company must be a C-corporation (not an LLC). Entrepreneurs who want QSBS treatment must specifically incorporate as a C-corp and meet all qualifying conditions from the date of issue of the stock.

Learn more about our company setup services →

2026 corporate update: US structures include C-corporations at 21% federal tax and potential QSBS eligibility, S-corporations with pass-through limits, LLCs with check-the-box flexibility and QBI access, partnerships and LLPs, and asset-protection vehicles such as Delaware Series LLCs and Wyoming/Nevada LLCs. OBBBA made 100% bonus depreciation permanent, restored domestic §174 R&E expensing, restored §163(j) to 30% EBITDA, and the US has not adopted Pillar Two IIR/UTPR/QDMTT.

EB-5 Investor Visa: Minimum investment of $800,000 (in Targeted Employment Areas) or $1,050,000 (other areas) creating 10 full-time US jobs. Direct path to Green Card. Processing times: 2–8 years depending on country of birth. O-1 Visa: For individuals with extraordinary ability in sciences, arts, education, business, or athletics. Employer-sponsored; 3-year initial period. L-1A Visa: For multinational executives and managers; requires 1+ year employment with the company abroad. EB-1C: Green Card for multinational executives/managers; requires L-1A history. E-2 Treaty Investor Visa: For nationals of treaty countries who invest "substantial" amounts in a US business; not a path to Green Card.

2026 residence update: US routes include EB-5, L-1A and EB-1C, L-1B, E-2 for treaty nationals, O-1, EB-1A, and B-1/B-2 visitors. Tax residency is separate from immigration and turns on the Substantial Presence Test or Green Card Test. Long-term green card status creates §877A exit-tax exposure when relinquished after 8 of 15 years.

US citizenship by naturalisation: 5 years of permanent residence (3 years for spouses of US citizens). Continuous residence, physical presence (30 months of 60 required), language (English), and civics knowledge requirements. US permits dual citizenship (does not require renunciation of foreign citizenship). US passport: visa-free access to approximately 186 countries.

JPMorgan Chase, Bank of America, Wells Fargo, Citibank, Goldman Sachs, Morgan Stanley — the major commercial and investment banks. Private banking: Goldman Sachs Private Wealth Management, Morgan Stanley Private Wealth, J.P. Morgan Private Bank, Northern Trust, Bessemer Trust for HNW clients. Account opening for legal US residents is accessible; for non-residents, increasingly difficult due to FATCA compliance costs.

For a relocation to United States, the local account is normally the operational account: rent, utilities, cards, domestic transfers, local tax or residence registrations, and evidence that the move is real. It should not automatically become the main wealth-management account unless the local banking system offers the depth, multi-currency capability, private-banking service level, and long-term stability required for the client's assets.

Account opening in United States should be treated as a compliance exercise, not as an administrative formality. Expect passport checks, proof of address, residence or visa documentation where applicable, tax-identification details, source-of-funds evidence, and sometimes in-person attendance or a local phone number. The easiest applications are those where the residence story, income source, and banking purpose are consistent before the first form is submitted.

Where to hold your main accounts

For non-US persons who have become US tax residents, primary US banking for US-dollar assets and US investment portfolios. Offshore banking (outside the US) for assets in other currencies — with full FBAR reporting on all offshore accounts above $10,000.

Learn more about our offshore banking services →

The US is the originator of FATCA — all foreign financial institutions with US-person account holders report to the IRS automatically.

United States is attractive when it is judged as a complete relocation platform, not as a slogan. The point is not that United States is perfect for everyone. The point is that, for the right person, the combination of tax position, residence practicality, lifestyle, geography, banking, language, and long-term stability can produce a genuinely coherent base.

• ›The world’s deepest market and opportunity engine. The United States is attractive because it remains the deepest market in the world: capital, customers, universities, technology, energy, property, and entrepreneurial culture.

• ›The lifestyle case is not cosmetic. The lifestyle depends entirely on state and city. Miami, Texas, New York, California, Arizona, and smaller low-tax states are different countries in practical terms.

• ›It can function as a real operating base. For entrepreneurs, investors, and returning Americans, the US offers scale, capital access, liquidity, and business formation opportunities unmatched elsewhere.

• ›It rewards the right profile. It suits people who can use the market and choose their state deliberately.

• ›The attraction has to be handled honestly. US tax, reporting, healthcare, litigation risk, and state-level variation are serious. The United States rewards those who choose location and structure with precision.

The United States is not one cost-of-living market. Miami, New York, Austin, Los Angeles, Phoenix and smaller states all produce different budgets, and tax is state-specific.

Typical monthly costs for an internationally mobile professional or family in the United States (2026 planning ranges):

• ›Comfortable single professional (no children): $6,000–10,500/month (£4,700–8,200 / €5,500–9,650)
• ›Family of four with private schooling: $15,000–28,000/month (£11,700–21,850 / €13,800–25,750)

These figures are planning ranges, not promises. The actual budget in the United States depends heavily on housing quality, neighbourhood, school choice, healthcare needs, car ownership, travel frequency, and whether you are trying to live like a local or maintain a Western expatriate standard.

Buying real estate in the United States can be useful for lifestyle, residence planning, and long-term anchoring, but it should not be treated as a simple shortcut to tax residence. Property is a factual tie; it can support a relocation story when used properly, but it can also create tax, inheritance, financing, and exit issues if bought before the wider plan is clear.

For internationally mobile buyers, the main points in the United States are:

• ›Ownership rules: Foreigners can generally buy property, but ownership does not create immigration status and can create US tax filings.
• ›Transaction costs: Closing costs vary by state and include title insurance, escrow, transfer taxes, legal fees, property tax, HOA fees, and insurance.
• ›Market and rental profile: Florida, Texas, New York, California, Arizona, and mountain states are entirely different tax and insurance environments.
• ›Residence and tax angle: Key issues include FIRPTA withholding on sale, estate tax exposure for non-residents, state taxes, hurricane/fire insurance, and whether the property creates residence ties.

The practical approach is to decide first whether the property is primarily for living, residence support, rental yield, asset protection, or lifestyle. Those are different purchases. A good real estate decision in the United States begins with title due diligence, tax-residence planning, inheritance review, and a realistic exit strategy — not with glossy developer brochures.

Transaction cost table (United States):

Retiring in the United States can make sense for the right profile, but it should not be reduced to a simple tax headline. The real question is whether the country gives you the right combination of residence security, pension treatment, healthcare access, cost of living, climate, and day-to-day comfort. A retirement move is harder to reverse than a business relocation, so practical quality of life matters as much as tax.

For retirees considering the United States, the main points are:

• ›Residence route: The practical route is usually the retirement in the US is straightforward for citizens and permanent residents, but immigration is a major barrier for foreign retirees without family or investment routes. This should be confirmed before making property commitments or moving assets, because a pleasant destination is not useful if the residence basis is weak.
• ›Pension income: Us residents are taxed on worldwide income; social security, iras, 401(k)s, roth accounts, and foreign pensions all need coordinated planning. The decisive point is often not only local tax, but whether the pension-paying country continues to tax the pension at source.
• ›Healthcare: Medicare is central from age 65, but gaps, supplements, and pre-65 insurance can be expensive. Retirees should arrange private insurance or a clear local healthcare pathway before arrival, especially where pre-existing conditions are involved.
• ›Cost of living and lifestyle: Huge regional choice, from florida and texas to mountain states and coastal cities, with very different taxes and costs. The country can work well where the retiree’s lifestyle expectations match the local rhythm rather than an imagined expatriate brochure.
• ›Climate and practical fit: Climate varies more than almost anywhere: tropical florida, desert southwest, snowy northeast, pacific coast, and everything between. Climate, language, bureaucracy, transport, and access to family often decide whether the move remains attractive after the first year.

The United States should therefore be assessed as a full retirement platform, not merely as a tax jurisdiction. The best candidates are retirees who have stable foreign income, good health coverage, a realistic view of local bureaucracy, and a clear plan for where they will live, how they will receive care, and how their pension will be taxed both locally and at source.

US citizens moving back to the United States from abroad are not ending US tax obligations — they are returning to the system that has applied to them all along. The key difference is that foreign-earned-income planning, foreign bank reporting, foreign pensions, offshore companies, and prior non-resident state positions must now be cleaned up before or during the move back.

Key considerations for US citizens returning to the United States:

• ›Foreign Earned Income Exclusion (FEIE): The FEIE may still apply for the part of a tax year in which you qualified abroad, but it does not shelter US-source income after your return. The timing of the move can therefore affect the final year of exclusion.
• ›Foreign Tax Credit: Foreign taxes paid before the return may still generate credits against US tax on the same income. Careful year-of-move allocation is important, especially where income is paid after departure but earned before departure.
• ›State tax residence: Returning to the United States often creates a state tax issue before it creates a federal issue. Your new state may tax worldwide income from the date residence begins, and your former state may argue that you never fully left if old ties remained.
• ›FBAR: Foreign bank accounts remain reportable for any year in which the aggregate balance exceeded $10,000, even if the accounts are closed before year-end. A move back is often the moment when old reporting gaps surface.
• ›FATCA: Form 8938 may still be required for foreign financial assets held during the year. Returning to the United States usually lowers the reporting thresholds, which can make assets reportable that were previously below the expatriate threshold.
• ›Foreign pensions and companies: Foreign pension plans, offshore companies, trusts, and investment wrappers should be reviewed before the move. Structures that were manageable while living abroad can become expensive or administratively painful once fully back inside the US system.

US citizens returning to the United States should work with a qualified US international tax adviser before closing the foreign chapter. The move back is not merely logistical; it is a tax transition that should be documented carefully.

• ›Pre-immigration planning for non-US persons: The single most important step is planning the US entry date and restructuring foreign assets before that date. Engage a US international tax attorney at least 6 months before moving to the US.
• ›State selection: Choose the US state of residence carefully. Zero-state-tax states (Florida, Texas, Nevada) save 0%–13.3% in state income tax vs California or New York on high incomes. Florida (Miami, Palm Beach) and Texas (Austin, Houston, Dallas) are the primary destinations for HNW individuals optimising combined federal + state burden.
• ›Recommended steps: 1. Engage US international tax attorney 6+ months before arrival. 2. Pre-immigration asset restructuring — realise foreign gains, step up basis, review foreign entity structures for CFC/PFIC exposure. 3. Obtain US visa (EB-5, O-1, L-1A, E-2, or other qualifying category). 4. Choose US state of residence — consider state income tax rates. 5. On arrival, establish US address and social security number. 6. Begin FBAR and FATCA compliance from day 1. 7. Engage US CPA for ongoing compliance.

The United States does not participate in the OECD Common Reporting Standard (CRS). A US bank holding your accounts is therefore not reporting under the standard OECD automatic exchange framework that applies in CRS jurisdictions. This is a factual observation, not a marketing point. The United States is not a CRS jurisdiction, and the absence of CRS reporting does not extinguish tax obligations anywhere else. It simply means CRS is not the relevant transparency channel for accounts held there.

This is the moment most people draw the wrong conclusion — because most people misunderstand how CRS works in the first place.

The common assumption is that CRS follows nationality. It does not. CRS follows tax residence. A Swedish passport does not trigger Swedish reporting. A German passport does not trigger German reporting. What matters is where you are tax resident at the moment your bank performs its due diligence — not the country on your passport, not the country you used to live in, not the country where your family still pays tax.

Once you understand that, the US picture becomes clear. A non-US citizen who has genuinely become tax resident in the United States is not reportable through US CRS channels because the United States is not operating as a CRS reporting jurisdiction in the first place. The real question is upstream: does Sweden, Germany, or any other prior country still regard the individual as tax resident under its own domestic rules? That is what determines tax exposure.

CRS creates transparency, not tax liability. The two are routinely confused. Even in a non-CRS jurisdiction, an unfinished or sloppy departure leaves your previous country in a position to tax your worldwide income — regardless of whether information is being exchanged automatically. The genuine risk is not the data flow. The genuine risk is a badly executed exit.

US citizens sit outside this framework entirely. Americans are not principally affected by CRS. They are affected by FATCA and by US citizenship-based taxation. For Americans, the passport really does follow you. A move abroad does not, by itself, end US tax filing and reporting obligations.

Upon establishing residence in the United States, you will need to obtain a SSN or ITIN from the competent local authority. This is required for most financial and legal transactions in the United States, including opening bank accounts, signing contracts, registering with tax authorities, and dealing with public offices.

You will also need to obtain or complete the relevant state ID / immigration status documentation process once your residence status has been approved. This document or registration record becomes your practical proof of residence in the United States and is usually required for banking, telecom contracts, utilities, leases, property transactions, and day-to-day administrative matters.

• ›Driving licences from most countries are accepted only for a limited period after arrival. Once you become resident in the United States, you should verify whether your licence can be exchanged directly or whether a local medical certificate, translation, theory test, or practical test is required.
• ›Health insurance should be arranged before arrival unless you are immediately covered by a local public system. In many cases, private international cover is the safest bridge solution while residence, employment, or social-security registration is still being completed.
• ›Importing personal effects should be planned before shipping anything to the United States. Household goods may qualify for relief when imported shortly after taking up residence, but customs paperwork, inventory lists, timing rules, and vehicle-import duties can make late or informal shipping expensive.
• ›Proof of address and banking are often linked. Banks, telecom providers, and government offices may require a lease, utility bill, local address certificate, or residence registration before they will open an account or complete onboarding.
• ›Ongoing local compliance should not be treated as an afterthought. Calendar reminders for residence renewals, tax registrations, local filings, health-insurance renewals, and address updates help prevent administrative problems that can later undermine the tax-residency position.

We offer comprehensive tax and legal support for your relocation to the United States. We follow a proven process — and where the United States requires specialist local input, we involve appropriately qualified local tax, legal, immigration, and banking advisers on the ground, while remaining responsible for overall coordination.

The results speak for themselves: we have helped over 100 entrepreneurs and business owners significantly reduce their tax burden through carefully planned relocations. Careful planning, thorough advice, and comprehensive support are our standard. Legally sound structuring within the framework of international tax law is our highest priority.

Our services typically include one or more of the following:

Our fees are generally billed on a time basis; fixed prices apply for certain services such as company formation.

As a first step, we recommend booking a consultation to discuss your plans — by phone, Zoom, or Signal. Together we find the best approach and establish contact with our local partner. As project coordinator, we keep all the threads in hand that are necessary for the successful implementation of your plans.