United States
World’s deepest capital markets — but worldwide taxation of citizens and green card holders is the trap most outsiders underestimate.
The position in figures.
Headline treatment for an individual tax resident. Source, asset and treaty rules can change the payable result.
Where the jurisdiction fits.
Best for
- Operators building US-market businesses where geographic proximity drives revenue
- Investors prioritising market access and venture/PE deal flow over tax efficiency
- Specific state strategies: Florida, Texas, Wyoming, Tennessee, South Dakota for 0% state income tax
- Holders of L-1, EB-5 or O-1 visas with a clear long-term US plan
Consider carefully
- Anyone who can build the same business elsewhere — US tax exposure compounds over time
- Long-term green card holders unaware that the expatriation regime can apply on departure
- HNWIs uncomfortable with the US estate tax regime (especially non-resident-alien $60k threshold on US-situs assets)
Programmes that matter.
EB-5 Investor Visa
Permanent residence via $800k investment in a Targeted Employment Area (or $1.05M elsewhere) creating ≥10 jobs. Conditional green card initially; backlogs vary by country of birth.
L-1 Intracompany Transfer
For executives, managers, or specialised-knowledge employees of multinationals. L-1A leads to EB-1C green card eligibility — one of the cleaner paths for entrepreneurs with an offshore parent company.
O-1 Extraordinary Ability
Non-immigrant visa for individuals with national or international acclaim in their field. Renewable indefinitely; can lead to EB-1A green card. Documentation-heavy but no investment requirement.
Pitfalls to resolve early.
- 01
US citizens and green card holders are taxed on worldwide income for life until they expatriate — and expatriation triggers a mark-to-market exit tax for "covered expatriates".
- 02
The Substantial Presence Test catches frequent visitors: 183 days under a weighted 3-year formula. Closer-Connection Statement (Form 8840) is the standard mitigation.
- 03
Non-resident aliens face a $60,000 estate-tax threshold on US-situs assets — including US-listed stocks held directly. Hold via foreign holding companies to mitigate.
- 04
GILTI and Subpart F can sweep foreign company profits into US shareholders’ taxable income annually, even without distribution.
- 05
The estate-tax exemption of $13.6M (2025) sunsets to roughly $7M on 1 January 2026 unless Congress acts.
Direct answers.
Do US citizens have to pay tax even when living abroad?
Yes. The US is one of two countries (with Eritrea) that taxes citizens on worldwide income regardless of residence. The Foreign Earned Income Exclusion (~$130k) and Foreign Tax Credit mitigate but rarely eliminate this.
How does the US exit tax work?
Citizens or long-term green card holders (8+ of the last 15 years) who expatriate and meet net-worth or tax-liability thresholds are "covered expatriates" — subject to a mark-to-market tax on worldwide assets above ~$865,000 (2025).
Which US states have no income tax?
Alaska, Florida, Nevada, New Hampshire (interest/dividends only, phasing out), South Dakota, Tennessee, Texas, Washington (capital gains tax on high earners since 2022), and Wyoming.
Can I just visit the US for under 183 days a year?
The Substantial Presence Test uses a weighted 3-year formula: all current-year days, 1/3 of last year’s, 1/6 of two years ago. Crossing 183 makes you tax resident — file Form 8840 promptly if claiming closer connection abroad.
How does the US tax foreign companies I own?
Subpart F and GILTI rules tax US shareholders of Controlled Foreign Corporations on certain types of income annually, even without distribution — this is one of the strictest CFC regimes in the world.
Continue the comparison.
Put United States against your current position.
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