High net worth individuals rarely evaluate a US immigration option without asking a second, equally important question. “What does this do to US taxes?”
With the Trump Gold Card now drawing attention as a potential pathway connected to US residency, the tax implications matter as much as the immigration mechanics. This article explains what sophisticated investors should think about, what can be planned, and where professional advice is essential before any move is made.
What the “Trump Gold Card” is, and why taxes are part of the first conversation
The website https://www.trumpcard.gov presents information about the Trump Gold Card. From a tax planning perspective, the critical point is not the branding. It is the individual’s potential US tax residency status and whether the individual becomes subject to the US tax system on a worldwide basis.
For high net worth individuals, US tax exposure can change dramatically based on immigration and presence. Even before any formal status is finalized, the steps they take, where they spend time, and how they structure assets can create avoidable risk.
They should treat any path that may lead to long-term US residence as a trigger for a coordinated review of immigration strategy, income tax, estate and gift tax, and cross-border reporting.
Two different “residencies” that people confuse
One of the most expensive mistakes affluent families make is assuming immigration status and tax status are the same thing. They are not.
Immigration residency is about whether the person has lawful permanent resident status or another right to live in the United States long-term.
Tax residency is about whether the IRS treats the person as a US resident for federal income tax purposes. A person may become a US tax resident even without a green card if they spend enough days in the US under the Substantial Presence Test.
This is why tax planning often starts before the move. A few “extra” trips to the US during the year can unintentionally tip someone into US tax residency earlier than expected.
For the IRS framework on resident versus nonresident alien status, see IRS guidance on determining alien tax status.
What typically changes once a high net worth individual becomes a US tax resident
When a person becomes a US tax resident, the United States generally taxes them on worldwide income, not only US-source income. This can include salary, business profits, interest, dividends, rental income, capital gains, and certain distributions from foreign entities.
For many high net worth individuals, the surprise is not that they owe tax. It is the breadth of what is included and the compliance footprint that comes with it.
Common changes once they are treated as a US tax resident include:
- Worldwide income reporting on a US Form 1040.
- Disclosure of foreign bank and financial accounts in many cases, including FBAR reporting through FinCEN.
- Reporting of foreign corporations, partnerships, or trusts that they own, control, or benefit from.
- Different tax treatment of investment products that were efficient abroad but unfavorable under US rules.
They should also understand that “living in the US” can shift the tax posture of family members and family offices, especially when decision-making and management begin to occur on US soil.
Worldwide income is only the beginning. Reporting is often the real burden
High net worth individuals often can manage the economic cost of tax. What can be disruptive is the compliance burden and the risk of penalties if reporting is missed.
Several reporting regimes can apply depending on facts, including foreign accounts, foreign entities, and foreign trusts. The reporting itself does not always create additional tax, but failures can create serious consequences.
They should work with a US cross-border CPA or tax attorney early to map their entire structure. It is far easier to reorganize before US tax residency begins than after.
Capital gains planning: timing matters more than people expect
US residents are generally taxed on capital gains from worldwide assets. For entrepreneurs and investors who hold large appreciated positions, timing becomes central.
If a person expects to become a US tax resident, they often ask whether gains accrued before residency will be taxed after they become resident. The answer depends on the asset, the transaction, and the timing. The United States typically taxes the gain realized while the person is a US resident, even if the appreciation occurred earlier, although special rules and treaty positions may affect specific cases.
That means “waiting to sell until after arrival” can create a materially different tax bill than selling before becoming a US tax resident. On the other hand, selling before arrival might trigger tax in another country, might be commercially undesirable, or could undermine long-term investment strategy.
They should treat this as an integrated planning exercise, not a last-minute choice made during travel week.
Business ownership and foreign companies: where many high net worth individuals get surprised
High net worth individuals often hold operating companies through non-US entities. Once they become US tax residents, US anti-deferral regimes can become relevant, and compliance requirements can expand.
Even without naming every technical rule, the practical takeaway is consistent. Foreign holding companies and offshore structures that were normal and efficient in a non-US context can become complex in a US context.
They should ask early questions such as:
- Will the foreign company generate income that is currently taxable in the US even if not distributed?
- Will dividends be taxed differently than expected due to entity classification or earnings pools?
- Does the individual’s ownership percentage trigger additional filings?
- Will moving management activities to the US create US tax presence for the company?
If they also intend to operate a US business, they should compare immigration options thoughtfully. Many entrepreneurs use the E-2 Investor Visa to start or acquire a US enterprise, but it is a nonimmigrant visa and it has its own planning posture. The tax analysis often differs depending on whether they remain a nonresident alien versus becoming a resident for tax purposes under presence rules.
For background on the E-2 category, see US Department of State treaty investor information.
US estate and gift tax: the issue many families overlook until it is too late
Income tax is only one side of the equation. For high net worth individuals, the more consequential exposure can be US estate and gift tax.
In broad terms, the US transfer tax system can apply very differently to nonresidents versus domiciliaries. A nonresident who is not domiciled in the United States may be subject to US estate tax primarily on certain US-situs assets. A person who becomes domiciled in the United States may be exposed on worldwide assets for transfer tax purposes.
Domicile is a facts-and-circumstances concept that can involve intent and ties. It is not always identical to immigration status or the number of days spent in the country.
For wealthy families, that distinction is critical. It influences:
- Whether worldwide assets can be included in a US taxable estate.
- Whether lifetime gifts trigger US gift tax rules.
- How trusts should be designed before a move.
They should coordinate with an attorney who handles cross-border estate planning, especially when the family has closely held businesses, significant investment portfolios, or multigenerational trusts.
Tax treaties can help, but they are not a universal shield
Many high net worth individuals come from countries that have an income tax treaty with the United States. Treaties can reduce double taxation, clarify residency “tiebreaker” positions in some cases, and set rules for certain categories of income.
However, they are not a universal solution. Treaties vary widely. Some countries do not have a treaty with the United States. Some treaty benefits require specific elections, disclosures, or positions that must be carefully supported.
They should have counsel review the relevant treaty article-by-article for their actual income streams, rather than assuming a treaty will automatically fix double tax issues.
The IRS maintains a list of US income tax treaties here: United States income tax treaties A to Z.
Pre-immigration planning: what is often done before US tax residency starts
Pre-immigration planning is not about aggressive tricks. It is about aligning structures, timing, and documentation with US rules before they apply.
Depending on the individual’s profile, planners may evaluate whether to:
- Restructure ownership of foreign entities to reduce compliance friction and unintended tax outcomes.
- Review investment holdings to identify products that receive unfavorable US treatment.
- Plan the timing of liquidity events such as a business sale, dividend recapitalization, or portfolio rebalancing.
- Evaluate trust planning to address future estate and gift tax exposure.
- Coordinate day counts and travel patterns to manage the Substantial Presence Test.
They should also ensure that documentation is clean. The US system often relies on forms, statements, and consistent reporting, and “informal” arrangements that worked elsewhere can become a risk.
What about state taxes: the hidden line item in high-cost states
Federal tax is only part of the picture. States can impose their own income taxes, and state residency rules can be strict.
A high net worth individual who settles in a high-tax state may face a very different outcome than someone who lives in a state with no personal income tax. In addition, states can scrutinize residency and domicile, particularly when the taxpayer keeps multiple homes.
They should consider where they will actually live, where their family will spend time, where they will register vehicles, and where social and business ties will be strongest. Those facts can matter in state residency audits.
Philanthropy and art: important, but not “tax neutral” by default
Many affluent families incorporate philanthropy into their US presence, whether through private foundations, donor-advised funds, or direct giving. The US tax system has specific rules on charitable deductions, valuation, and substantiation.
Similarly, art collections and other passion assets raise questions about importation, sales tax, valuation, and estate planning. A family that relocates to the US may find that storing or exhibiting art in the United States changes their compliance needs.
They should treat these areas as part of the overall planning, not as side projects handled after arrival.
How this interacts with investor immigration and entrepreneurship planning
Immigration planning and tax planning should move together, especially for those considering US immigration through investment or an entrepreneur visa USA strategy.
For example, a person pursuing an E-2 visa USA may focus on E-2 visa requirements such as a substantial investment, a real operating enterprise, and the intent to depart when E-2 status ends. Tax residency, however, may still happen if they spend enough time in the United States, and it can happen even if their visa is technically “nonimmigrant.”
That is why sophisticated investors should build a timeline that includes:
- When they expect to begin spending significant time in the United States.
- When a spouse and children may relocate, enroll in school, or buy property.
- When the US business will start generating revenue and payroll.
- When they plan to sell assets, receive large distributions, or exit a company.
When the timeline is mapped correctly, they can often reduce surprises and avoid creating tax residency earlier than intended.
Common misconceptions high net worth individuals should avoid
High net worth individuals often hear confident statements from friends, online forums, or overseas advisors who do not work with US rules daily. Several assumptions deserve a reality check.
- “If it is earned outside the US, the IRS cannot touch it.” If they are US tax residents, worldwide income is generally in scope.
- “If they keep money offshore, it stays invisible.” Reporting regimes can apply regardless of where the money sits.
- “A visa is not a green card, so taxes do not change.” Tax residency can be triggered by day count even without permanent residence.
- “They can fix the structure later.” Planning after they become US tax residents is often harder and can be more expensive.
Practical questions an advisor will ask before any major move
A high quality cross-border team will usually start with fundamentals. They will not begin with complicated tactics. They will begin with fact gathering.
Questions often include:
- Which passports and tax residencies do they currently have?
- How many days do they expect to spend in the US this year and next year?
- What are the major income sources, and where are they sourced?
- Do they own foreign corporations, partnerships, or trusts?
- Are there upcoming liquidity events, such as a business sale or IPO?
- Where will they live in the US, and what state tax regime applies?
They should be prepared to share an accurate balance sheet and entity chart. If those documents do not exist, creating them is often the first valuable step.
A careful note about “new card” programs and tax certainty
High net worth individuals should be cautious about assuming that any new program, proposal, or branded initiative automatically comes with special tax treatment. US tax obligations generally come from the Internal Revenue Code, Treasury regulations, IRS guidance, and relevant treaties. Immigration pathways can influence when someone becomes a resident or how long they intend to stay, but they do not automatically rewrite tax law.
That is why it is wise for them to treat the Trump Gold Card as a planning prompt. If it changes the likelihood of living in the US long-term, then it changes what tax planning should happen now.
Actionable next steps for high net worth individuals considering the Trump Gold Card
If they are seriously evaluating a US move connected to the Trump Gold Card, they should avoid informal planning. A structured process can protect privacy, reduce stress, and prevent expensive rework.
- Build a two-year travel forecast to understand when US tax residency could be triggered under day-count rules.
- Commission a US tax “diagnostic” that reviews worldwide income, entity ownership, trusts, and reporting exposure.
- Align immigration and tax timelines so that business launches, asset sales, and family relocation do not accidentally create tax outcomes they did not intend.
- Review estate planning early, especially if the family plans to establish long-term ties in the US.
They should also decide who is the “quarterback” for the process. In many cases, it is a coordinated team that includes an immigration attorney, a cross-border tax advisor, and an estate planning attorney who understands international families.
Before they take any step that increases US presence or signals long-term intent, they should ask a simple question that prevents most surprises: if they become a US tax resident next year, is their current global structure designed for the US tax system, or designed for somewhere else?
Please Note: This blog is intended solely for informational purposes and should not be regarded as legal advice. As always, it is advisable to consult with an experienced immigration attorney and a Certified Public Accountant (CPA) or tax professional for personalized guidance based on your specific circumstances.