Italy and Portugal consistently appear at the top of shortlists for globally mobile entrepreneurs seeking European residency.
However, these two programs are built on fundamentally different logics: one is designed for founders who actively build and operate a business, while the other is aimed at investors deploying capital into regulated vehicles.
This comparison is not about which program is “better” in absolute terms—it’s about which aligns with your capital structure, operational appetite, time horizon, and lifestyle objectives.
Why the EU—and Why Now
European residency programs offer something the H-1B system does not: detachment from employer sponsorship and a defined legal pathway to permanence.
Portugal’s Golden Visa is frequently considered by Indian professionals because it allows residency through qualifying investment rather than employment, requires limited physical presence, and permits family inclusion from the outset.
For professionals accustomed to immigration status being tied to quarterly performance reviews or restructuring cycles, the contrast is material: residency rights are no longer dependent on a single employer, and long-term planning becomes possible again.
Investment thresholds—often around €500,000 for regulated fund routes, though not universally fixed across all qualifying structures—can appear high in isolation.
In practice, many applicants view them in the context of decades of constrained mobility, delayed asset decisions, and family uncertainty in the US.
Managing US Assets Before the Move
Transitioning jurisdictions involves far more than immigration filings. US-based assets require careful sequencing before any change in tax residency or immigration status.
Key considerations typically include:
* Timing of equity or asset sales relative to departure
* Treatment of 401(k), IRA, RSUs, and stock options
* Ongoing US filing obligations during transition years
* Currency exposure as assets shift from USD to EUR
* Decisions around retaining or disposing of US real estate
Errors in sequencing—rather than the decisions themselves—are what most often create avoidable tax friction or long-term compliance issues.
Understanding US Exit Tax Rules
Exit tax considerations apply only to US citizens and “long-term residents”—defined as green card holders for at least 8 of the prior 15 tax years. They do not apply to H-1B holders or other non-immigrants, regardless of net worth.
For those subject to the regime, IRC §877A imposes a mark-to-market exit tax on certain unrealized gains. Thresholds are indexed annually for inflation. For reference, covered expatriate status is triggered if one or more tests are met, including:
* Average annual US income tax liability above the indexed threshold (e.g., ~$206,000 for 2025, increasing in subsequent years), or
* Net worth of $2 million or more, or
* Failure to certify tax compliance.
An exclusion amount—also indexed annually (e.g., ~$890,000 for 2025)—reduces the amount of gain subject to tax.
While many professionals fall below these thresholds, it is not accurate to assume most expatriates face no exit tax.
Long-term residents with appreciated securities, equity compensation, or concentrated investment portfolios may still be classified as covered expatriates, even if cash flow is modest.
For H-1B holders without green cards, exit tax rules do not apply—but coordination with US tax advisors remains essential to manage final-year filings, sourcing rules, and dual-status returns.
Family Planning and Timing
Golden Visa programs typically allow inclusion of spouses and dependent children, but dependency definitions and age limits vary by jurisdiction.
Children approaching adulthood may need to be included before specific cut-off dates to preserve eligibility.
Education planning, spousal employment rights, and the logistics of maintaining overlapping ties to the US and EU during a transition phase require advance coordination. In many cases, families establish EU residency while continuing to work in the US temporarily, creating flexibility rather than forcing an immediate exit.
Banking and Currency Considerations
Former US residents remain subject to FATCA reporting, which some European banks are better equipped to handle than others. Early engagement with banks experienced in US-connected clients reduces friction during account opening and fund transfers.
Currency diversification—gradually shifting exposure from USD to EUR—should be approached as a financial planning decision, not merely a by-product of immigration.
Common Mistakes to Avoid
Treating the Golden Visa as a standalone decision.
Residency planning intersects with tax, asset structuring, family timing, and compliance. Each element affects the others.
Assuming immigration status alone solves risk.
Without coordinated tax and asset planning, mobility gains can be offset by avoidable financial consequences.
Rushing the transition.
After years of uncertainty, the impulse to move quickly is understandable—but haste often creates issues that measured planning avoids.
When to Start Planning
For most professionals, meaningful planning begins 12–24 months before a desired transition point. This window allows parallel execution of EU residency preparation and US tax planning, including final-year sourcing, asset timing, and document readiness.
The objective is not to abandon one system for another overnight, but to build optionality—so decisions are made on your terms rather than under deadline pressure.
Key Takeaways
This is not simply an immigration decision. It is a long-term structuring decision that affects where your family can live, work, study, and invest over decades.
Many H-1B holders delay permanent decisions—home ownership, long-term investments, or geographic roots—because of systemic uncertainty. European residency offers an alternative framework: predictable timelines, family inclusion, and independence from employer sponsorship.
When planned correctly, the transition from the US to the EU can restore control over mobility and long-term strategy.
The outcome depends less on the visa itself than on the sequencing of tax, assets, and residency planning around it.
Marlow Bray advises globally mobile professionals on residency and citizenship planning. For a confidential assessment of your transition options, contact our advisory team.
