Tax Planning
& Cross-Border Strategy.
Tax-residency planning, exit-tax mitigation, and ongoing cross-border tax compliance — coordinated with the family's existing tax counsel. We are a planning practice, not licensed tax preparers; we do not file returns.
A second passport is only valuable if the tax position works.
Tax-residency planning
A residency-by-investment programme grants the legal right to reside, but tax residency is a separate analysis. We model the family's tax-residency position before, during, and after migration — physical-presence days, primary-home test, vital-interests test (for civil-law jurisdictions), and tie-breaker provisions in any applicable double-tax treaty.
Exit-tax mitigation
Some jurisdictions impose an exit tax on departing residents — most notably the US §877A "expatriation tax" for covered expatriates, France's exit tax on deferred capital gains, and various Asian regimes. We coordinate with home-jurisdiction tax counsel on timing, asset-base reset opportunities, and (where available) treaty-based mitigation.
Cross-border compliance
Ongoing obligations after migration: FATCA / CRS reporting in the new jurisdiction, continuing home-jurisdiction reporting where applicable (US persons forever, UK statutory residence test transitions), VAT / GST registration where business activity follows the principal, and treaty-based withholding-tax reclaims.
Substance briefs
A tax-residency claim is only as defensible as the substance behind it. For every residency stack, we produce a written substance brief — primary home, dependants' schooling, banking centre of gravity, social-security arrangements, club memberships, healthcare provider, and physical-presence calendar. Defensible under any tax-authority audit.
Your tax planning engagement, step by step
Discovery call
A 30-minute call with a senior advisor. We map your situation, scope the tax planning brief, and confirm the right service mix.
What clients say about our tax planning work
"Citizen Sure guided our family through Malta citizenship with exceptional professionalism. We now hold EU passports — the process was seamless from first consultation to passport in hand."
"Speed and certainty were our priorities. They secured UAE Golden Visas for our entire family in under three weeks. Their government relationships and due diligence process were genuinely impeccable."
"Two years into our Portugal Golden Visa journey, we're on track for EU citizenship. The investment has already paid for itself many times over in business opportunities and lifestyle freedom."
"I was initially sceptical about the process, but the team's expertise and transparency gave me complete confidence. Our Caribbean passports arrived in 58 days, exactly as promised."
Not automatically. Programmes like the UAE Golden Visa, Portugal Golden Visa, and Caribbean CBI programmes grant the LEGAL RIGHT to reside; whether you become a TAX resident depends on the destination jurisdiction's tax-residency tests. The UAE has no individual income tax (and no corporate tax for most personal income), so tax-residency is mostly procedural. Portugal applies a 183-day test plus a habitual-residence test; achieving Portuguese tax-residency unlocks the NHR-2.0 regime for qualifying activities. Singapore applies a more complex test under IRAS. Tax-residency is a separate engagement from the migration application itself.
The original Non-Habitual Resident (NHR) regime closed to new applicants on 31 December 2023. The successor regime — informally called NHR-2.0, formally the Tax Incentive for Scientific Research and Innovation (IFICI) — launched 2024 with narrower scope. It offers a 20% flat rate on qualifying employment / self-employment income (in scientific research, innovation, certain skilled occupations) and exemption on most foreign-source income for 10 years. Eligibility is more restrictive than the original NHR — most pure-investor profiles do not qualify under IFICI. We model the realistic position before recommending Portuguese tax-residency.
§877A applies to "covered expatriates" — US citizens or long-term green-card holders who renounce / abandon and meet either an income, net-worth ($2M+), or tax-compliance test. The covered expatriate is treated as having sold all worldwide assets at fair market value the day before expatriation; the resulting gain is taxed at long-term capital-gains rates (with a $X exemption indexed annually). Pension and IRA balances are treated as fully distributed. Mitigation options are limited but real — gifting prior to renunciation, asset-base step-up planning, expatriation timing relative to mark-to-market events. We coordinate with US tax counsel on every covered-expatriate case; we do not represent the client before the IRS ourselves.
No — home-country tax residency typically requires ACTIVE termination, not just acquisition of foreign residency. The UK Statutory Residence Test (FA 2013) sets out specific tests; Indian RNOR rules apply for two years post-departure; US tax-residency continues until renunciation of citizenship or formal abandonment of green-card status. A "tax-resident-of-nowhere" position is rare and requires careful structuring. Most families end up tax-resident in the destination jurisdiction with continuing reporting obligations to the home jurisdiction (FATCA, CRS). The substance brief documents the tax-residency position the family is claiming.
No. Citizen Sure is a tax-PLANNING practice, not a tax-filing firm. We produce planning memos, substance briefs, and structuring recommendations; we do not prepare or file tax returns. Many of our clients retain their existing accountants for filing; we coordinate with them through the engagement. For new-jurisdiction filings (e.g. Portuguese IRS submissions, UAE corporate tax filings, US Form 1040 / 8938 / FBAR), we make introductions to qualified local filers.
Speak to a senior advisor — free, confidential, 30 minutes.
Every tax planningengagement begins with a discovery call. We’ll listen to your situation, ask the questions that matter, and respond with a clear recommendation on the right next step — including programme shortlist, cost estimate, and indicative timeline.
- Senior advisor on every callNot a sales rep — a partner-level practitioner with direct authority.
- Strict NDA on every engagementYour case never leaves the firm; full confidentiality guaranteed.
- Independent — no developer commissionsOur recommendation answers only to you, never to a programme operator.
Latest from our research desk
Market reports, regulatory alerts, and programme updates relevant to tax planning.
Cross-Border Tax Planning for Investment Migration
A second passport is only as valuable as the tax position behind it. Citizen Sure's tax-planning practice handles tax-residency analysis, exit-tax mitigation, substance briefs, and ongoing cross-border compliance for investment-migration clients. We are a planning practice — we do not file tax returns. Coordination with home-jurisdiction tax counsel (US §877A specialists for covered expatriates, UK statutory-residence-test counsel, Indian RNOR specialists, etc.) is built into every engagement. Active jurisdictions in scope include the UAE (zero personal income tax), Portugal NHR / IFICI (the successor 2024 regime), Cyprus non-dom, Italy flat-tax regime (€100,000 / €200,000), Greek non-dom, Singapore IRAS, and a range of Caribbean tax-neutral residencies. Speak to a senior advisor for a confidential consultation.
Speak with our Tax team
Independent tax advisors who work with you and your existing accountants — never replace them.