High-net-worth Americans are increasingly looking beyond the United States for residence, tax planning, lifestyle, and second citizenship options. The trend is driven by a mix of political polarization, state-level tax changes, citizenship-based taxation, and the desire for a stronger international backup plan.
For many wealthy U.S. families, the move is not only about reducing taxes. It is also about finding a more stable lifestyle, protecting mobility, and creating optionality for their families and businesses.
The United States is unusual because it taxes citizens on worldwide income even when they live abroad. Only the United States and Eritrea operate this kind of citizenship-based tax system. This means Americans who move overseas usually still need to file with the IRS and deal with U.S. tax reporting, even if they are resident elsewhere.
That makes the American case different from other wealthy migrants. Moving to Portugal, Italy, Greece, the United Kingdom, Switzerland, Panama, Paraguay, Colombia, Puerto Rico, or Monaco may change lifestyle and local tax exposure, but it does not automatically remove U.S. tax obligations.
Several forces are pushing wealthy Americans to look abroad:
- Political division at federal and state level
- Concern over future tax increases
- Capital gains tax changes in states such as Washington
- Wealth tax concerns in California
- Business exits or liquidity events
- Desire for a new lifestyle chapter
- Interest in second or third citizenship
- Concerns about banking access and investment limits linked to U.S. citizenship
- A wish to “ride out the storm” during a turbulent period in the U.S.
State-level taxation is a major concern. Washington, previously seen as tax-friendly, introduced a capital gains tax. California has moved forward with taxes aimed at billionaires. The concern among some wealthy families is not only the current tax level, but the direction of travel. Once a high threshold is introduced, they worry it may later be lowered to capture more people.
Europe is one of the main destinations. The appeal is not always purely tax-driven. Many Americans are attracted by lifestyle, culture, health, longevity, education, safety, and access to major cities.
Portugal has already attracted many Americans, especially in Lisbon and Cascais. However, Portugal’s original NHR program has closed. A more limited version now exists, but it mainly helps people in innovation, science, or similar sectors. Portugal is also becoming less attractive for those seeking citizenship quickly, with proposed or reported changes extending the citizenship timeline from five years to ten years.
Italy has become one of the major beneficiaries. Its lump-sum tax regime allows qualifying residents to pay a fixed annual amount in exchange for exemption from global taxation. The annual amount has increased over time, reportedly from €100,000 to €200,000 and then €300,000. Demand has come not only from Americans, but also from other high-net-worth migrants leaving or avoiding other jurisdictions.
Milan and northern Italy are especially popular because they combine European lifestyle, business access, culture, and tax planning.
Greece is another option. Its lump-sum tax regime is attractive because it is described as costing around €100,000 per year. For wealthy Americans who want a European base, Greece offers Athens, Thessaloniki, and island living, along with a Mediterranean lifestyle. The appeal includes climate, diet, health, and longevity.
The United Kingdom remains relevant despite changes to its non-dom regime. The UK now has a shorter four-year non-dom-style program. While this made the UK less attractive to some non-Americans, it may still interest Americans because U.S. citizens are already taxed globally and the UK change may not affect them in the same way.
Switzerland remains one of the most established wealth-preservation destinations. Zurich and Geneva continue to attract high-net-worth and ultra-high-net-worth Americans. Some negotiate arrangements with specific cantons to secure favorable residency and tax treatment. Switzerland has long been one of the most desired destinations for wealthy Americans.
Puerto Rico is another important option, although it is not the same as fully leaving the United States. It offers a different tax environment and has attracted wealthy Americans for years. However, some who moved there are now looking elsewhere because of infrastructure issues.
Monaco also appears as an option, though demand is more limited. It remains relevant for those seeking a high-end European base with strong wealth appeal.
Latin America is also part of the trend. Because of proximity and time zones, some Americans look at Panama, Colombia, and Paraguay. These countries can offer easier access from the U.S. and may suit families or business owners who want to stay close to North America.
For many wealthy Americans, the long-term goal is not only residence but citizenship. A second citizenship can provide a backup passport, more mobility, and, in some cases, the option to consider renouncing U.S. citizenship later.
However, renouncing U.S. citizenship is a major step. Many wealthy Americans do not seriously consider it until they have another strong passport with similar travel and consular benefits. Even then, the process can be costly and complex.
The U.S. exit tax is one of the biggest barriers. Under Section 877A of the Internal Revenue Code, a “covered expatriate” may be treated as if they sold all worldwide assets on the day they give up citizenship. Unrealized gains above the exemption amount, stated as around $900,000, may be taxed at relevant rates.
For high-net-worth individuals, this can create a major tax cost. It also means that timing matters. Someone who obtains a second citizenship before building significant wealth may have more flexibility later, but most people do not know in advance whether they will become very wealthy unless they expect inheritance or a major liquidity event.
The foreign earned income exclusion can help some Americans abroad, but it has limits. It does not eliminate the broader filing burden or the wider tax complexity faced by wealthy U.S. citizens. For many, the paperwork itself becomes one of the most frustrating parts of life abroad.
Banking is another issue. U.S. citizens can face restrictions from foreign banks because of U.S. reporting obligations. Some banks avoid American clients, while others accept them but limit investment products to simple, low-risk options.
The decision to leave the U.S. or create an international backup plan depends on several factors:
- Current and expected net worth
- Whether a liquidity event has already happened
- Family needs and children’s education
- Desired lifestyle and climate
- Tax exposure in the U.S. and abroad
- Access to banking and investments
- Strength of any future second passport
- Citizenship timeline
- Exit tax exposure
- Tolerance for bureaucracy
- Long-term plans for business and residence
The main countries benefiting from this trend are those that combine lifestyle, tax planning, stability, and a credible path to residence or citizenship. Italy, Greece, Portugal, Switzerland, the UK, Puerto Rico, Panama, Paraguay, Colombia, and Monaco all appear in the current migration picture, but each serves a different type of American migrant.
The key caveat is that moving abroad does not automatically solve the U.S. tax problem. For Americans, residence planning, citizenship planning, tax planning, and exit planning are separate questions. A second residence may improve lifestyle. A second citizenship may improve optionality. But only giving up U.S. citizenship can fully change the citizenship-based tax position, and that step may trigger serious costs.
For wealthy Americans, the practical lesson is to plan early. Many residence, citizenship, and tax residency programs have become more expensive, more restrictive, or closed entirely. Portugal’s NHR changes, Italy’s lump-sum tax increase, and longer citizenship timelines show that attractive programs can change quickly.
The best strategy depends on whether the goal is lifestyle, tax efficiency, citizenship, family security, or a full long-term exit from the U.S. For most people, the first step is not renunciation, but building optionality through residence, tax residency, and a credible second passport route.
