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Residence

Why residence, citizenship and tax residency are not one question

Residence, citizenship and tax residency are often treated as one decision, although they solve very different family problems.

Mediterranean homes along a rocky coastline

Why residence, citizenship and tax residency are not one question

When I first began thinking seriously about where our family should live next, I carried one large question in my head: which country should we choose? Somehow every other decision became part of it. Where should we obtain residence, set up a company, pay tax, keep money, educate the children and, ideally, acquire a second passport? I wanted one country to solve most of these problems so that we could build the rest of our life around it.

My own experience dismantled that logic quite quickly. Two of my children were born in the United States and are American citizens. We have lived in Thailand for a long time, and I became tax resident here. At different stages I set up companies in the UAE, Hong Kong, Georgia and elsewhere. I considered France, Spain, Italy, the United States, the UAE and Portugal as places to live, while researching several routes to residence and citizenship.

Instead of one country, I ended up with a map. That was when I saw that the original question had been wrong.

Europe made this especially clear. A ranking or an expat article is never enough for me. I try to picture an ordinary day, and often I will rent a place, walk through different neighbourhoods and talk to people who live there. After 87 moves, I tend to know fairly quickly whether I can imagine a life somewhere.

Spain did not work for me. I have spent time in Madrid and Barcelona and understand why so many people love them, but I did not want either city to become our main family base. Italy feels entirely different. Still, if Spain offered our family a particularly strong legal or educational route, I would examine it. I would no longer assume that a good residence programme meant we had to move there.

The right to live in a country and the desire to live there have become separate decisions. Thailand shows the reverse. We actually live here, understand the country from within and know both the advantages and the compromises. That knowledge bears little resemblance to reading ten expat guides. Even so, a country that suits us now does not have to be the answer for the next twenty years.

The same distinction applies to passports. When a child is born in the United States and becomes an American citizen, the immediate reaction is simple: the child has a strong passport. As the children grow, that passport becomes part of a much longer story involving universities, the right to live and work in the US, and a particular educational path. At the same time, I have to think about my youngest child, my wife and my own status if the United States is to become one of our main family bases.

Citizenship for two children did not solve my immigration position. If we move before the children can affect their parents' status, I will still need an independent route. One family can contain several immigration trajectories, each with a different timetable. They somehow have to meet.

Taxes created the greatest confusion for me. Anyone exploring international life soon encounters the supposedly magical number 183. It is so neat that people are tempted to build an entire strategy around it. The more I learned about my own position and cross-border structures, the less comfortable I became with universal formulas.

I had companies and bank accounts in several jurisdictions, a Russian passport, a family living with me and a business serving international clients. Today I am tax resident in Thailand. If we move to the United States or Italy, the tax picture will change with our real life.

I now find it more sensible to decide honestly where I intend to live, and then work with tax specialists on a structure that fits that reality. Tax still matters, particularly when income is high enough for the difference between jurisdictions to become substantial. But I have watched people choose a life from a tax table and later discover that they do not enjoy the life they bought. That trade feels too expensive to me.

Companies taught me something similar. I have formed businesses in the UAE, Hong Kong, Georgia, Kyrgyzstan, Uzbekistan, Thailand and the United States, and researched Singapore and several offshore jurisdictions. Each decision had a practical reason at the time: banking, tax, access to a market or workable payments.

A company does not necessarily need to live where its owner sleeps. Sometimes keeping everything in one jurisdiction is the cleanest answer. In other cases, the business genuinely functions better elsewhere. The real work is understanding how that decision interacts with personal tax residency, controlled foreign company rules, the source of income and the laws of the countries involved.

This is why I value good tax lawyers. Nomad Nova should not pretend to replace them. The more international planning I do, the more respect I have for people who have spent their careers mastering one field. What matters is giving them the right problem to solve.

If I put my own family on the table, the questions become concrete. There are five of us. Two children are US citizens and the youngest is not. We live in Thailand. I run an international online business. I am considering the United States as a possible future base, feel personally close to Italy and want Asia to remain part of our lives. Around that sit decisions about the business, tax, schools, property and my own immigration status.

An American immigration lawyer will solve the American part. An Italian specialist will produce good Italian options. An adviser in the UAE can explain the advantages of structuring there. All of them may be right, while the final decision still belongs to me.

Today I would begin with four separate questions. Where do we want to live? Where do we need the right to live? Which citizenships could matter to the family over the long term? Given that life, where does tax residency arise and how should the business be organised? Only after answering them separately would I join the answers together.

Skipping that step creates much of the chaos I see among international entrepreneurs. Someone has residence in one country, a company in a second, a bank account in a third and an apartment in a fourth. Every element once had a good reason, but nobody has asked whether the collection still suits the family's next ten years.

I am rebuilding my own map for exactly that reason. It is also why Nomad Nova interests me more than conventional immigration consulting. I want to understand the person's life first, then take each part of the problem to the specialist who can handle it properly.

Obtaining one more residence permit can be relatively easy. Knowing what it is meant to do for your family is much harder.

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