What tax haven countries can
Americans move to and get citizenship?
The core need behind a question like this is an individual's
desire to legally reduce their taxes. A lot of moving parts come with such a
complicated question, so let’s break it down.
First and foremost is the question of moving, which conjures up
ideas of packing your belongings and relocating your entire life to one new
location. The solution is much simpler — and slightly more complicated
You can spend that time in as many countries as you like and
still qualify for a tax exclusion of $105,900 on active personal income as of
this year.
Not everyone enjoys the nomadic life. Some folks just want to
pack up and move to one country where they don’t have to pay tax. This is where
tax havens become more important.
It is best if where you live and where you incorporate your
business are two different places. There are several reasons for this that are
best understood by example, so let’s look at the difference between personal
income versus corporate tax havens
Personal Income Tax Havens
Three main types of tax havens exist
where you can live full-time without being taxed by the local government.
Zero-tax countries, or countries with
a personal income tax rate of zero, are what most people are referring to when
they talk about tax havens. Many of them are unappealing as a place to live
long-term, and the few that are appealing have strict entry requirements.
Territorial tax countries use a
system of taxation that only taxes local-source income, or money earned from
working within the country. Depending on how you earn and personally take your
income, a territorial tax country could allow you to live tax-free.
Tax-exempt countries normally tax
their residents, usually at very high rates, but create exemptions for
qualifying individuals. These programs often have an expiration date.
For example, Portugal’s non-habitual
residence tax scheme allows you to live tax-free in the country for a total of
10 years. Once the 10 years are up, you will be taxed at the same rates as
everyone else in Portugal.
Corporate Tax Havens
If you want to pay zero corporate
tax, you only have one option: incorporate your business in a corporate tax
haven. In some cases, you cannot live in these countries due to the laws.
For example, a Hong Kong corporation
will be taxed at a rate of 16.5% if you live there, but if you live somewhere
else, your corporation will enjoy zero tax.
In other cases, you’ll have
difficulty getting into the country, due to your age, nationality or the cost
of entry. Even if you’re wealthy, a desirable but expensive tax haven like the
Cayman Islands might be within your reach but may not be your best choice.
One way or another, there are
downsides to personally living in most corporate tax havens. Thankfully, you
can still incorporate your business in these countries and enjoy a zero-tax
lifestyle somewhere else.
Balancing The Equation
Moving to a tax haven is less like
picking a spot on the map and more like balancing a delicate equation. To fully
eliminate your taxes, both parts of the equation must work together.
For instance, if you set up a Belize
company and stay in the U.S., the Belize company setup is essentially worthless
because you would still have to pay tax in the U.S. on everything your company
earned as a CFC.
You must optimize both sides of the
equation.
You can do this by finding a country
to personally live in that meets one of the criteria we’ve discussed — zero
tax, territorial tax or tax exemptions — and then setting your company up in a
corporate tax haven.
For everyone except U.S. citizens, it
usually is this simple. But U.S. citizens are not as lucky. This is where the
final piece of the equation comes into play: citizenship.
The Citizenship Problem
The U.S. is, effectively, the only
country in the world that taxes its citizens based on citizenship. The Foreign
Earned Income Exclusion offers a slight reprieve, but for those who earn any
passive income or make more than $105,900 a year, there is no way to avoid
further taxation.
The only way out is to renounce your
U.S. citizenship. Until it’s removed from the equation, you cannot legally
eliminate your taxes. But before you can do that, you must obtain a second
citizenship.
If you are willing to move around to
avoid becoming a tax resident in any one country, you can get a second
citizenship in one of dozens of countries, renounce your U.S. citizenship and
then become a tax non-resident in your new home country.
If you don’t want the nomad life,
you’ll need to get citizenship in a tax haven. Unfortunately, most zero-tax
countries are not going to grant you citizenship. Some simply do not give
citizenship to foreigners, others want a large check and others require you to
live there for over a decade before you can become a citizen.
You might be able to find citizenship
in a territorial tax country. Yet countries like Panama that offer citizenship
on paper do not have a great track record of fulfilling that promise.
Other territorial tax countries like
Nicaragua may not fit the tax haven description that you’re imagining.
None of these countries are going to
grant citizenship right away, and you’ll be stuck paying taxes in the U.S. for
at least another five years, if not six or seven considering the processing
time to finalize your citizenship.
If you’re content paying taxes for a
few more years while you wait, then you can move to a tax haven, structure your
business to maximize tax benefits, wait the allotted time, claim your new
citizenship and then renounce your U.S. citizenship.
If you do not want to wait, the best
way to speed up the process is via citizenship by investment. These programs
vary widely in terms of cost, location and desirability.
St. Kitts and Nevis has one of the
fastest and best value programs. For a donation of $150,000, you can become a
citizen of St. Kitts and Nevis in four to five months.
If you are in a hurry, you can pay an
extra fee to get it in 60 days. This is one case where you could live, work and
set up your business all in one country, because St. Kitts will not tax you or
your business no matter where you live.
What If I Don’t Want to Renounce My
Citizenship?
Finally, if you do not want to
renounce your U.S. citizenship, you may be able to move to Puerto Rico and
enjoy single-digit tax rates of about 4%. However, you must commit to spending
most of your time in Puerto Rico.
It needs to be your bona fide home.
You won’t realize the savings
immediately after moving there, but you will start the clock toward eliminating
or reducing your taxes on both passive and active income. In that sense, Puerto
Rico is a tax haven of sorts for Americans.
Puerto Rico’s Act 20 and 22 are for
folks who want to remain a U.S. citizen but also pay very low tax rates without
having to bother with everything else we’ve discussed. But it is only going to
work for certain types of people: those with a bigger business they want to
sell soon, crypto investors, hedge fund managers, big traders or anyone with
large capital gains.
If you want to use Puerto Rico as a
tax haven, you need to do proper planning.
Conclusion
The misconceptions surrounding what
it means to move to a tax haven may lead to confusion and oversimplification of
a decision that is quite complex. For U.S. citizens, especially, those who
truly want the benefits of a tax-free life must sacrifice other things.
Where you live, where you incorporate
your business, what citizenships you possess, where you qualify as a tax
resident and many other factors all must be considered before you can legally
and permanently eliminate your taxes. It is not a decision to take lightly or
something that can be planned overnight.
If you really want tax freedom, you
must do the work and invest in professionals who can help you determine exactly
how to balance the equation and come out on top.
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