Residency and Citizenship: Why the Wealthy Buy Options Across Borders
The Million Dollar Question: Henley & Partners — the firm that handles most of the world’s high-end residency and citizenship-by-investment applications — has seen the share of its client requests coming from US nationals grow from about 5% in 2018 to roughly what share by 2025?
A) 12% B) 22% C) 30% D) 40%Read on for the answer.
The market for second residencies and second passports is not the cloak-and-dagger world the press tends to paint. It is a portfolio decision — four overlapping markets that wealthy buyers stack, the way an investor stacks asset classes. This post walks through what they actually buy in 2026, what each piece costs, what the new constraints look like after the year the European Court of Justice killed Malta, and why the buyer profile has quietly shifted toward the United States.
What it is
The wealthy don’t buy “a passport.” They buy across four overlapping markets, and most serious buyers end up holding pieces of all four at once.
Citizenship-by-investment (CBI) sells the actual passport — permanent, in most cases inheritable, the strongest mobility product on the market. The Caribbean CBI programs are the canonical examples; until 29 April 2025, Malta sold one too. The price is a one-time contribution, the document is for life, and the buyer’s children typically inherit the same status.
Residency-by-investment — “golden visas” — sells a renewable residence permit, not citizenship. The permit is conditional on continuing to satisfy the investment and (usually) some minimum-presence requirement. Lose the underlying asset or fall below the presence threshold and the permit can go away. Most golden-visa countries also offer a separate, slower naturalization path that can convert the permit into a passport after a five-to-ten-year wait.
Tax-residency regimes — Italy’s non-dom flat tax, Switzerland’s forfait fiscal, the UK’s now-defunct non-dom regime — sell a tax position rather than a travel document. The buyer becomes tax-resident in the country and gets a special, capped treatment of foreign income.
Inbound US visas — EB-5 and, since late 2025, the Trump Gold Card — sell a green card. The US calls these immigration programs; in the global-mobility market they sit alongside everything else as just another product.
The buyers don’t pick one. A typical UHNW stack might be a Caribbean CBI passport (mobility), a UAE golden visa (residence with no minimum stay), and an Italian flat-tax election (tax position) — three different products in three different jurisdictions, each doing a different job. Among themselves the buyers don’t call it “Plan B.” They call it “optionality,” and they price it as insurance.
Who uses it
The wealth bands sort the buyers by what they can afford to stack.
Below $5M. Rare for full CBI. The headline contribution alone — $200K–$300K — is a meaningful share of net worth. Buyers in this band who go through with it usually do a Caribbean program because their first passport is weak and the visa-free travel uplift is worth the spend. Most stay at the level of a long-term visa or a non-investment residency route.
$5M–$30M. The entry tier for serious mobility planning. A Caribbean passport for travel, a Portugal D7 or D8 visa for a European foothold, a Greek golden visa, an Italian non-dom election if the foreign-income flow justifies it. One or two products, lightly stacked.
$30M–$100M. The sweet spot for the US route — EB-5 in a Targeted Employment Area at $800,000, or the Gold Card at $1 million. Buyers in this band often also hold Swiss lump-sum residency, and increasingly run more than one golden visa simultaneously. The stack starts to look like a real portfolio.
$100M+. Full portfolio approach: passports in two or three countries, residencies in four to six, family members spread across separate jurisdictions for redundancy. Spouses are often booked into different programs to maximize the family’s combined optionality.
$1B+. Family offices that retain dedicated immigration counsel as a permanent line item. The global-mobility plan is structured around expected political windows — the program likely to close, the tax regime likely to be cut, the geography likely to become harder to reach. The single most expensive part of the stack is rarely the contribution; it is the substance — the apartments, schools, and presence-day calendar that make the residencies stick.
The shift that matters more than the bands is who is doing the buying. Through 2014–2022 the dominant client was wealthy Russian. Through 2015–2021 it was wealthy Chinese. Since 2024, it has been wealthy American. Henley & Partners reports that applications from US nationals grew from about 5% of all client requests in 2018 to nearly 40% in 2025 — roughly a 2,400% jump in the share. By the third quarter of 2025, US-national applications to Henley were already 67% higher than the full-year total for 2024. A spring 2025 Harris poll found that nearly half of all Americans, and two-thirds of Gen Z and Millennial respondents, expressed interest in dual citizenship. That feeds back up into the wealth advisor’s conversation: by the time a wealth manager fields a residency question in 2026, the client is statistically much more likely to hold a US passport than a Russian or Chinese one.
Why they use it
Five drivers, in roughly the order buyers themselves rank them.
Mobility. Visa-free travel is the most visible product. The 2026 Henley Passport Index puts Singapore at the top with visa-free or visa-on-arrival access to roughly 193 destinations. Japan, South Korea, and the UAE sit just behind at 187. Most of continental Europe, the UK, the US, Australia, and Canada cluster in the 180–185 range. At the bottom, Afghanistan provides access to about 23 destinations. The gap between top and bottom is what CBI programs sell — buyers from weaker-passport countries pay six figures for the difference.
Tax. This is the driver that most justifies the math at higher wealth bands. Italy’s non-dom flat tax — newly raised to roughly $325,000 a year for arrivals after the 2026 budget law (the statute denominates it as €300,000, with €50,000 per family member) — caps a buyer’s Italian tax bill on all foreign-sourced income regardless of how much that income actually is. The regime runs for 15 years, exempts foreign assets from Italian wealth and inheritance taxes, and waives the foreign-asset reporting that would normally come with Italian tax residency. Switzerland’s forfait fiscal taxes the resident on living expenses rather than worldwide income — the higher of roughly $485,000 (CHF 435,000, the 2026 federal floor), seven times annual rent, three times pension cost, or actual household spend. The UK’s old non-dom regime, which served roughly the same purpose, was abolished in April 2025 and pushed part of London’s wealthy population in search of a replacement. Italy and Switzerland inherited much of the displaced demand.
Risk diversification. Concentration in any single country’s politics, currency, judiciary, healthcare system, and policy whim is, at sufficient scale, a portfolio risk like any other. Second residency is the hedge. The driver is not “I am leaving;” it is “I do not have to be here if the calculus changes.”
Family. EU residency gives the next generation in-state tuition at European universities (still a $300,000-plus saving over four years against US private-college sticker prices). UK residency opens the boarding-school pipeline. A spouse’s family in another country, future inheritance planning, and the calculus of where adult children will eventually want to settle all push the stack toward more than one jurisdiction.
Time-zone and lifestyle arbitrage. The Gulf for tax and business hours overlapping both Europe and Asia, Switzerland or Italy for quality of life and proximity to Europe’s medical and educational infrastructure, the Caribbean for actual sun and an Atlantic-facing tax-friendly jurisdiction. None of these is a single answer. The stack is the answer.
How it works
Walk the products one by one.
Caribbean CBI. The five Eastern Caribbean states — St Kitts & Nevis, Antigua & Barbuda, Dominica, Grenada, and Saint Lucia — agreed in 2024 to a US$200,000 floor on the headline contribution. In 2026, Antigua starts at $230,000 to its National Development Fund, $260,000 via a University of the West Indies contribution, or $300,000 in approved real estate. St Kitts starts at $250,000 to its Sustainable Growth Fund or $325,000 in approved real estate. Processing runs four to ten months depending on the country. The resulting passport ranks roughly 25th to 35th globally on visa-free travel, with access to about 150 to 165 destinations including the entire Schengen Area, the UK (depending on the program), and most of Asia. CBI applicants are not required to live in the country.
Portugal. The golden visa still exists but the real-estate route ended in October 2023 under the More Housing reform. Investors now use venture-capital fund routes starting around $540,000 (€500,000), capital transfer routes, or a job-creation route. The bigger change came in the spring of 2026: the Portuguese parliament passed a new Nationality Law on 1 April 2026, promulgated 3 May, doubling the path to naturalization for most foreign nationals from five years to ten. The residency itself still confers Schengen access and the ability to bring family, but the citizenship clock now runs more slowly than the buyer-side marketing built up in 2017–2022. Roughly 20,000 golden-visa applicants are still waiting for appointments with AIMA, Portugal’s migration agency, with processing times that have stretched past three years.
Spain. Closed. Spain’s golden visa shut down on 3 April 2025 under Law 1/2025 and no new applications are accepted. Existing permit holders are grandfathered.
Greece. Still open. Greece overhauled its golden visa in September 2024 with a zone-based pricing system: roughly $870,000 of real estate (€800,000) in Athens, Thessaloniki, Mykonos, Santorini, and any island with more than 3,100 inhabitants; about $435,000 (€400,000) in lower-demand zones. Greece is currently sitting on a backlog of roughly 42,000 pending applications and is legislating its way through it.
Malta. Gone at the CBI level. The European Court of Justice ruled on 29 April 2025 that Malta’s golden-passport program — under which roughly 5,300 applicants had naturalized in exchange for contributions and investments that raised about $1.5 billion over the program’s lifetime — was incompatible with EU law because it conferred EU citizenship in exchange for predetermined payments without requiring a real link between the applicant and the country. The Maltese government has since announced a merit-based naturalization route to replace it; the easy-money pathway is closed.
UAE Golden Visa. AED 2 million (approximately USD 550,000) in real estate buys a 10-year residence permit with no minimum-stay requirement and no employer sponsor. Since February 2026, the AED 2 million is measured as the total property value certified by the Dubai Land Department, regardless of any mortgage balance. The visa can be extended in 10-year blocks as long as the underlying investment remains. Spouse, parents, and children can all be sponsored on the same residency.
Italian non-dom flat tax. Zero investment required for entry. The buyer relocates Italian tax residency to Italy and elects into the regime; they then pay roughly $325,000 a year (about $55,000 per dependent) on all foreign-sourced income, regardless of how large that income is. Italian-sourced income is taxed normally. The regime runs 15 years and exempts foreign assets from Italian wealth, inheritance, and gift taxes. Buyers who entered before the 2026 increase pay the rate that was in effect when they arrived.
Swiss lump-sum forfait. Available in 21 of Switzerland’s 26 cantons. The buyer must not engage in gainful employment in Switzerland; foreign business activity is permitted. The tax base is the higher of roughly $485,000 (the 2026 federal floor), seven times annual rent, three times pension cost, or actual household expenditure. High-cost cantons like Geneva and Vaud often push the effective base higher. The regime is renewable indefinitely.
US EB-5. $800,000 in a project in a Targeted Employment Area (rural or high-unemployment) or $1,050,000 in a non-TEA project, with regional center administrative fees commonly running $50,000 to $100,000 on top, plus government filing fees ($11,160 for the I-526E plus a $1,000 RIA fee). The capital must create at least 10 jobs and remain at risk for several years. The result is conditional permanent residence, converted to permanent residence and eventually citizenship via the standard naturalization path. The thresholds are scheduled for inflation adjustment in 2027.
Trump Gold Card. Launched in late 2025 after a year of trailers. The deal: a $1 million “gift” to the US federal government per individual (or $2 million paid by a corporate sponsor for an employee), plus a $15,000 non-refundable DHS processing fee. Successful applicants receive EB-1 or EB-2 immigrant visa status — green card on issuance. The program relies on a legal restructuring of existing EB categories rather than new statutory authority. As of May 2026, 338 individuals had applied and 165 had paid the $15,000 vetting fee, per DHS reporting.
What it costs
All-in numbers per product, including contribution, government fees, and a normal due-diligence and legal layer. Headline contribution alone is rarely the buyer’s actual bill.
Caribbean CBI. $230,000–$400,000 for a single applicant. Scales to roughly $400,000–$600,000 for a family of four. Real-estate routes can be larger ($300,000–$500,000 in property), but the buyer holds an asset they can theoretically sell after a five-to-seven-year hold.
Portugal golden visa (fund route). Roughly $540,000 in the qualifying fund, plus $35,000–$75,000 in legal and program fees. The citizenship clock is now ten years, which materially shifts the deal versus the older five-year terms.
Greek golden visa. $435,000–$870,000 in real estate, plus 5%–10% in transaction taxes and legal fees. The buyer holds an asset.
UAE golden visa. Roughly $550,000 in property (recoverable on sale), plus about $1,500–$3,000 in administrative fees. The most efficient of the residency products if the buyer is comfortable holding Dubai real estate.
Italian non-dom flat tax. Zero entry cost. About $325,000/year recurring, $55,000/dependent. Substance — an Italian address, real presence — adds another layer of cost that does not show up in the regime itself.
Swiss forfait. Zero entry cost. About $485,000+/year recurring (CHF 435,000+, the 2026 federal floor), often higher in expensive cantons. The buyer must rent or own a Swiss home appropriate to the assumed standard of living, which the cantonal authorities use to set the effective base.
EB-5. $800,000 invested (recoverable but illiquid for five to seven years) plus $50,000–$100,000 in administrative fees plus roughly $20,000 in filing and legal.
Trump Gold Card. $1,000,000 non-refundable to the US Treasury, plus $15,000 processing, plus counsel. The capital does not come back.
Then there is the professional layer. Henley & Partners’ published structure puts per-file fees that can exceed $100,000 for full-service handling on complex stacks. Midmarket firms run $25,000–$60,000. CBI-only specialists run $10,000–$25,000. A buyer properly stacking three products across two or three jurisdictions runs a total bill of roughly $500,000 to $2 million, before annual carrying costs like the Italian or Swiss tax bill.
Read against the assets being protected, the cost is small. Read in isolation, it is a year’s worth of luxury spending.
Hidden costs and tradeoffs
Five things the brochures don’t lead with.
Tax exit risk. The US taxes its citizens on worldwide income regardless of where they live, which makes giving up a US passport unusually expensive. The expatriation tax under IRC §877A is a one-time, mark-to-market levy on appreciated assets above an inflation-adjusted exclusion — roughly $890,000 of net gain in 2025 dollars — and applies to high-net-worth expatriates by definition. The exit tax routinely catches sellers by surprise mid-process. For US-passport-holding buyers, the practical implication is that the second passport is for optionality, not for actually renouncing the first. The renouncing happens only when the math has been done very carefully, and usually only after several years of planning.
Substance requirements. Tax authorities are sharper than they were a decade ago about treating “paper residency” as not real. Italian tax residency requires more than 183 days in-country or a real Italian habitual abode. Switzerland’s forfait requires that you do not work in Switzerland at all. Portugal’s program requires only seven days a year, but the citizenship path requires that you actually integrate. The cost of meeting substance is rent, time, and a real apartment, on top of the program fees.
The “Plan B that becomes a tax bill” failure mode. Buying residency in a country that taxes worldwide income — without electing into a flat-tax or forfait regime — can convert the asset into a liability if the buyer trips a residency trigger before they intended to. The substance rules cut both ways: they make the residency real, and they make the tax real.
Reputational and banking friction. Holding a CBI passport increasingly draws regulatory scrutiny from EU banks and US compliance officers. Some Schengen border officers now ask CBI-passport holders for supporting documentation that EU-native passport holders are not asked for. The product still works, but it is not friction-free in a way the marketing implies.
The illiquid investment trap. EB-5 capital sits in a project for five to seven years and has historically defaulted in some regional center cases. The Greek and Portuguese real-estate routes lock the buyer into specific properties or funds, which may underperform broader market benchmarks because the buyer’s hand is tied. The contribution-style programs — Caribbean National Development Funds, the Trump Gold Card “gift,” Italy’s annual flat tax payment — avoid this. The money is simply gone, but the buyer is not holding an illiquid receipt that may or may not pay them back. Which structure is preferable depends on whether the buyer wants the money to work or wants it to be done.
What people get wrong
It is rarely a single product. The press story is “the wealthy buy a passport.” The actual buying behavior is a stack: residency in one jurisdiction, passport in a second, tax residence in a third, the whole structure built around where the family lives, where the children go to school, where the operating businesses are, and where the family’s bankers and lawyers actually sit. Treating residency-and-citizenship as a one-decision product misses the basic architecture of how the buyers think about it.
Citizenship and residency are not the same product. A golden visa is a renewable permit conditional on continuing to satisfy the investment and presence rules. A passport is permanent and (usually) inheritable. The two are often conflated in headlines, but they trade at very different prices and carry very different risk profiles. Losing a residency is a paperwork event. Losing a citizenship — short of fraud at the time of naturalization, or, in the EU’s emerging stance, the underlying program itself being declared illegal — is much harder.
The buyer profile shifted, and the industry’s language hasn’t caught up. The dominant client in 2024–2026 is American, not Russian or Chinese. Wealth advisors who frame second-citizenship conversations the way they did in 2018 — as products for people fleeing authoritarian states — miss what their US clients are actually asking for, which is closer to a financial hedge with a real-estate component.
“Plan B” is the wrong framing. Buyers don’t think of it as escape; they think of it as optionality, the same way a CFO holds working capital in multiple currencies. The framing as escape both misses the math — the cost of holding optionality is small relative to the assets it hedges — and the motivation, because most buyers never use the option. They just like having it.
The EU is closing the easy doors faster than new ones are opening. Malta is gone. Spain is gone. Portugal has doubled its citizenship clock. Cyprus has been gone since 2020. The Caribbean and the Gulf are doing more of the work that European programs used to do, but the Caribbean passports rank lower on visa-free travel than the EU passports they replace. The product is not getting cheaper at the high end; it is getting more constrained, and the buyers who do the planning earliest are the ones who get the best deal.
Bottom line
The Million Dollar Question’s answer is D — about 40%. The headline shift in this market is not the rules. It is who is now buying. The dominant client for a high-end residency and citizenship advisor in 2026 is no longer a Russian or a Chinese national hedging political risk in their home country. It is increasingly an American buying a hedge against domestic political volatility, healthcare cost, and the policy whim of an administration that may or may not be the one in office five years from now.
That demographic shift has pulled the market up the wealth curve, where the stacks have gotten more elaborate and the products have gotten more constrained. The doors that are open in 2026 run through the UAE, Italy, Switzerland, the Trump Gold Card, and the Caribbean. The doors that used to dominate the conversation — Malta, Spain, the easy Portugal route — have closed. The wealthy now do not buy one residency the way they once bought one second home. They buy a portfolio of jurisdictions, weighed by tax exposure, family geography, business reach, and travel access, the same way they balance an investment portfolio.
The cost of buying optionality is small relative to the assets it hedges. The cost of not having it, in a year when Henley is forecasting 165,000 millionaires to physically relocate — the most ever recorded — is what the rest of the market is now pricing.
Related reading:
- Taxes: How Wealth Is Structured and Preserved — the broader tax architecture that non-dom and forfait regimes plug into.
- Privacy: Why the Wealthy Value Invisibility — second residency as a privacy product.
- Houses: First Homes, Second Homes, and Estates — the housing decisions that flow from where the family is resident.
- Tech Wealth: How Founders and Investors Live Differently — founders are a fast-growing share of the global-mobility market.
