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International & Expat

Territorial Residency (UAE, Panama, Portugal NHR)

Establish residency in a 0-tax or territorial-tax country to escape US state tax + optimize CFC.

Overview

Territorial-tax countries only tax income sourced IN their country: UAE (0% personal), Panama (0% foreign), Portugal NHR (10% for 10 years, replaced by IFICI in 2024), Malaysia, Costa Rica, Georgia (0% for foreign remote work). Doesn't erase US worldwide tax (§911 helps), but eliminates state tax + provides second-passport optionality. Requires physical presence, real ties, often golden-visa investment.

Best fit
Digital nomadsHigh-net-worth pre-liquidity foundersRetirees seeking geoarbitrage
Estimated impact
Eliminate 5–13% state tax + optimize CFC/GILTI structuring

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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