The U.S. Investor Migration Report

Executive summary

American families are not looking for a second passport. They are looking for the right not to live inside a system that works against them. A passport is the most concrete tool that question produces — but the question itself is older, and it is human. It is what people have always done when the framework they inherited stopped serving the lives they were trying to build.

This report exists for the family asking the practical version of that question — given that we are not leaving, and given that we cannot opt out of U.S. taxation, what does Plan B actually look like for us in 2026? Three findings stand out from this year's review of nine widely-discussed residency and citizenship programs:

1. One question publicly reported families ask is not "which passport opens the most doors" but "which passport opens the United States to my children if they ever need that door." (General information, not advice.) Four of the nine programs lead to citizenship in a country that has an E-2 treaty with the U.S.: Portugal, Italy, New Zealand, and Panama. The other five do not — including, perhaps surprisingly, Greece (E-1 treader status only) and the entire UK Overseas Territories cluster (Cayman and Anguilla are explicitly excluded from the UK E-2 treaty).

2. The cheapest credible E-2-path option for an American family in 2026 is not where you would expect. Italy's Investor Visa starts at €250,000 in a qualifying innovative startup — meaningfully less than Portugal's Golden Visa (€500K fund) or New Zealand's Active Investor Plus (NZD 5–10M). Italy's path to citizenship is long (10 years), but the threshold to enter the system is the lowest of the E-2-path group.

3. The legislative ground has moved in the last 18 months, and the direction is generally toward higher cost, longer timelines, and more scrutiny. The most consequential change: Portugal's residence-to-citizenship period was doubled from 5 to 10 years (signed into law 3 May 2026). Right behind it: Malta's MEIN direct-citizenship program was struck down by the Court of Justice of the European Union on 29 April 2025 and is suspended. Anyone considering either country must plan against the new rules, not the rules in older write-ups.

A summary scoring of all nine programs against six axes (cost, time to residency, time to citizenship, U.S.-tax fit, mobility, and legislative stability) appears in Section 4. Per-program detail with sources appears in Section 5.

1. Why this report exists

For an American with assets, the second-passport conversation has moved out of the financial-news margins and into mainstream wealth planning. The IRS publishes a quarterly list of citizens who renounce; quarterly counts have repeatedly exceeded 1,000 in 2024–2026. Inquiries to Caribbean Citizenship-by-Investment units from U.S. passport holders rose more than threefold between 2020 and 2024 according to multiple program-administrator statements reported in major outlets. The U.S. Department of State's E-2 treaty list was extended to include Portugal in 2024, a small but materially significant change for American families considering long-horizon options for their children.

What is conspicuously missing from much of the public conversation is a comparison written specifically from an American taxpayer's perspective. Most program literature is written for a generic "internationally mobile HNW individual." But an American is not a generic HNW individual:

• According to publicly available IRS guidance, the United States taxes its citizens on worldwide income, and foreign residence by itself does not change that filing obligation. The "tax-haven residency" framing commonly used in non-U.S. marketing materials therefore applies differently to U.S. persons. (General information, not tax advice — consult a U.S.-qualified CPA.)
• Publicly reported sources note that U.S. anti-abuse and reporting regimes (CFC, GILTI, PFIC, FBAR, Form 8938, expatriation tax under §877A) interact with foreign residency in ways that publicly reported practitioners describe as technically demanding. (General information, not tax advice.)
• According to IRS proposed regulations published 26 June 2023, certain Maltese personal pension schemes are identified as listed transactions. Per the IRS, listed-transaction classification carries specific reporting consequences described in IRS guidance. (General information, not tax advice — consult a U.S.-qualified CPA regarding any specific transaction.)

This report attempts the comparison from that perspective.

2. What this report does — and does not do

This report does: - Compare nine residency and citizenship programs against six axes that publicly reported American HNW families commonly weigh. - Cite, for every cost figure and timeline figure, an official government source or a U.S. federal agency source. Where a figure is a market estimate (e.g., legal fees), it is labelled ESTIMATE. - Compute a single composite score per program — the Plan B Readiness Score — using openly published weights so a reader can disagree with our weights and re-rank the table. - Flag U.S.-specific tax considerations on each program.

This report does not: - Recommend any specific program for any specific family. Program suitability depends on facts (citizenship of spouse, ages of children, source and structure of wealth, business interests, residence and tax history) that publicly reported practitioners say a published report cannot evaluate, and that only licensed counsel engaged by the reader can assess. - Compute its own visa-free travel scores. Where mobility figures are cited, they are taken from publicly aggregated bilateral visa agreements (commonly indexed on Wikipedia's Visa requirements for [country] citizens pages, which in turn cite each country's ministry of foreign affairs). Travel mobility for any single passport changes frequently and should be re-checked. - Provide tax projections, fee quotes, or legal opinions. These require licensed professionals in both countries.

The nine programs covered: Portugal (Golden Visa, with reference to D7), Italy (Investor Visa), Greece (Golden Visa), Malta (Permanent Residence Programme; MEIN reference), Cyprus (Permanent Residency by Investment), New Zealand (Active Investor Plus), Cayman Islands (Certificate of Permanent Residence for Persons of Independent Means), Panama (Qualified Investor Visa), Anguilla (ARBI and HVR). These nine were chosen because each is the most commonly considered route in its category, has stable enough public documentation to research responsibly, and is geographically distributed across the four regions American families most commonly look at: Western Europe, the South Pacific, the Caribbean, and Central America.

3. Methodology — six axes and the Plan B Readiness Score

For each program, we collected data on six axes. The data sources are listed in Section 11; per-program detail is in Section 5.

The six axes:

Plan B Readiness Score: weights and formula

Each axis is scored 0–10 for each program (10 = best for an American family on that axis). The composite is a weighted sum:

Why these weights: The U.S.-tax fit axis is weighted highest because, according to publicly available IRS guidance, U.S. citizens remain subject to U.S. worldwide taxation regardless of foreign residence; programs whose standard structures publicly reported sources describe as drawing IRS scrutiny tend, in Truvon's editorial view, to produce administrative burden disproportionate to the program's other features. (Editorial commentary, not tax advice.) Legislative stability is second because the cost of a program that gets restructured (or shut down) mid-application is the entire cost; Malta's MEIN is the case study. Cost, time-to-citizenship, and mobility share the next tier because they each materially shape the outcome without dominating it. Time to PR is weighted lowest because most programs deliver PR within a year; differences here are real but not decisive.

The weights are open. A reader who disagrees can re-weight the same axis scores and produce a different ranking honestly.

Scoring rubrics (abbreviated)

• Cost (capital deployed by family of 4): 10 = under $200K · 8 = $200–400K · 6 = $400–700K · 4 = $700K–$2M · 3 = $2–3M · 2 = $3–5M · 1 = >$5M.
• Time to PR: 10 = 1–3 mo · 9 = 4–6 mo · 8 = 7–12 mo · 7 = 12–18 mo · 6 = 18–24 mo · 5 = 2–3 yr · 4 = 3–4 yr · 3 = 4–5 yr · 2 = 5+ yr.
• Time to citizenship: 10 = under 2 yr · 9 = 2–3 · 8 = 3–4 · 7 = 4–5 · 6 = 5–7 · 5 = 7–10 · 4 = 10–12 · 3 = 12–15 · 2 = 15+ · 1 = no defined path.
• U.S.-tax fit (composite): 10 = E-2 treaty + modern U.S. tax treaty + no specific IRS scrutiny · 9 = E-2 + modern treaty · 7 = E-2 only, no income treaty · 5 = no E-2, modern treaty · 4 = no E-2, old or weak treaty · 3 = no E-2, no income treaty (FATCA-only) · 1 = active IRS scrutiny of the program's standard structures.
• Mobility: 10 = 180+ destinations · 8 = 160–179 · 6 = 140–159 · 4 = under 140 · 0 = no passport upgrade obtainable in foreseeable horizon.
• Legislative stability: 10 = no material changes in 36 months · 8 = minor changes · 6 = moderate changes · 4 = high volatility · 2 = major restructuring or program suspended.

4. The nine programs at a glance

Composite Plan B Readiness Scores (out of 10), ranked. Numbers in parentheses indicate Truvon's score on each of the six axes (Cost / PR / Citizenship / U.S.-tax fit / Mobility / Stability).

A few observations on the ranking:

• Italy's first place is non-obvious and worth pausing on. It is not the fastest, not the highest-mobility, and not the most prestigious option. It wins because it combines a very low entry cost (€250K), an E-2 treaty already in force, a modern U.S. tax treaty, and a program structure that has been stable for years. Italy's main weakness is a 10-year path to citizenship — but the program does what an American family most often wants: it gives the family a low-cost, low-risk foothold in the EU with E-2 optionality for the children, and it does not require betting that the program will still exist in five years.
• Portugal D7 ranks above Portugal's Golden Visa in our scoring. The Golden Visa offers no faster path to citizenship than the D7 (both face the new 10-year clock), the D7 has no investment threshold, and both share the same E-2 access. For a family that can demonstrate qualifying passive income, the D7 is the more cost-efficient way to get into the same naturalisation queue.
• The Caribbean / UK-Overseas-Territory cluster is heterogeneous. Anguilla's stability and very low cost on the donation route put it in the upper half despite its weakness on U.S.-tax fit. Cayman, by contrast, requires roughly $2.5M of capital deployment and offers no E-2 path, which produces a lower score.
• Malta MPRP scores at the bottom because its citizenship path effectively does not exist post-CJEU ruling. The PR program itself is operational and well-administered, but for a family whose objective is a passport, Malta has moved out of the answer set. We include it for completeness and to flag the change.

5. Programs in detail

Each program below follows the same structure: cost, time to PR, time to citizenship, E-2 status, family inclusion, U.S.-tax interaction, recent legislative changes, and mobility. Each fact is sourced; sources are collected in Section 11.

5.1 Portugal Golden Visa (with D7 reference)

The basics. Portugal's Residence-by-Investment scheme (the Golden Visa) was substantially restructured by the Mais Habitação law (Law 56/2023) effective 7 October 2023. The residential real-estate routes were removed. The remaining qualifying routes are dominated by €500,000 in a regulated venture-capital or private-equity fund with no real-estate exposure. The D7 visa is a parallel, income-based residence route requiring qualifying passive income (Portuguese minimum wage levels, scaled for family size). Both lead to the same naturalisation clock.

All-in cost, family of 4. - Golden Visa, fund route: investment €500,000 + government fees (AIMA processing + residence-permit issuance + renewals across 5 years, family of 4) approximately €40,000–55,000 (ESTIMATE — exact fee schedule was last revised by AIMA portaria in 2024) + legal/admin/fund-subscription approximately €30,000–60,000. All-in 5-year estimate ~€575,000–620,000 (~$620,000–670,000). - D7: no investment. Required passive income for a family of 4 ~€18,800/year demonstrable. Government fees ~€100 visa + ~€170 residence permit per person. Legal/admin ~$10,000–20,000 total.

Time to PR / EU long-term resident. Statutory five years of legal residence (Article 80, Foreigners Act). Practical AIMA processing backlogs of 18–36 months have been documented in 2024–2026.

Time to citizenship. Recently doubled from 5 to 10 years for non-EU/non-CPLP nationals, signed 3 May 2026. EU and CPLP (Lusophone) nationals: 7 years. The clock now starts at issuance of the residence permit, not application submission. For an American applicant filing after the law takes effect, citizenship eligibility is approximately a 10-year horizon.

E-2 status. Portugal has E-2 (and E-1) treaty status, granted by Public Law 117-263 (signed 23 December 2022); E visas issuable to Portuguese nationals from 15 March 2024.

Family inclusion. Spouse or registered partner; minor children; dependent adult children up to age 26 if single, financially dependent, and full-time students; dependent parents of either spouse (parents under 65 must show financial dependency; parents 65+ qualify without the test). A 2025 reform requires the main applicant to complete 2 years of residency before sponsoring adult-dependent reunification (with exceptions for spouses and minor children).

U.S. tax interaction. A U.S.–Portugal income tax treaty has been in force since 1994. The saving clause preserves U.S. worldwide taxation of citizens. CFC/GILTI/PFIC continue to apply. Portugal's NHR non-habitual resident regime closed to new entrants on 31 December 2023 and was replaced by the narrower IFICI regime (under Ordinance 352/2024/1), which offers a 20% flat IRS rate on Portuguese employment income for 10 years but is restricted to specific qualifying activities (science, innovation, certain highly skilled professions). Publicly reported tax practitioners have observed that, for many U.S. persons, IFICI's narrower scope provides less benefit than the prior NHR regime. (General information, not tax advice.)

Legislative stability 2023–2026. High volatility: Mais Habitação (October 2023), NHR closed (December 2023), SEF dissolved and replaced by AIMA (November 2023), IFICI in force (January 2024), 2025 family-reunification tightening, citizenship doubled to 10 years (3 May 2026).

Mobility. Portuguese passport: approximately 184 visa-free or visa-on-arrival destinations plus full EEA + Switzerland freedom of movement.

For an American family. The single distinguishing feature is the E-2 treaty (active since March 2024), which materially de-risks future U.S. business establishment for Portuguese-citizen family members. The cost is competitive within Western Europe. The disadvantages are the freshly doubled naturalisation timeline and the loss of NHR's tax appeal.

5.2 Malta MPRP — with MEIN reference

The basics. Malta's Maltese Exceptional Investor Naturalisation (MEIN), the direct-citizenship-by-investment program, was suspended on 29 April 2025 following the Court of Justice of the European Union's judgment in Case C-181/23 (European Commission v. Republic of Malta). The Court ruled that Malta's program breached Article 20 TFEU and Article 4(3) TEU by operating "a transactional naturalisation procedure that commodified EU citizenship." Pre-existing approvals remain valid. The Government of Malta stated it would "respect the decision" and rebuild a compliant framework, but no replacement direct-investment-to-citizenship route had been published as of May 2026.

The operational route for new applicants is now the Malta Permanent Residence Programme (MPRP) — a residency-only route, restructured by Legal Notice 146 of 2025.

All-in cost, family of 4, MPRP. - Government contribution: €37,000 (uniform — purchase or rent). - Administrative fee: €60,000 (€15,000 submission + €45,000 approval). - Property: purchase ≥ €375,000 (nationwide) OR lease ≥ €14,000/year for 5 years. - Philanthropic donation: €2,000. - Additional government admin fee per adult child / parent / grandparent: €7,500. - Due diligence ~€15,000; legal/agent fees market ~€20,000–40,000. - All-in 5-year, purchase route, family of 4 (two minor kids): ~€500,000–540,000 (~$540,000–585,000). - All-in 5-year, lease route: ~€200,000–230,000 + ~€70,000 rent over 5 years (~$290,000–320,000).

Time to PR. MPRP grants permanent residency directly upon approval. Processing typically 6–9 months.

Time to citizenship. With MEIN suspended, the only available route is ordinary naturalisation: 5 years of legal residence in the 7 years preceding application, including the 12 months immediately before application. This requires substantive physical presence, Maltese or English language, and integration — it is discretionary and not a guaranteed outcome. Practical horizon: 5–7+ years with no certainty.

E-2 status. Malta is not on the U.S. State Department E-2 treaty list. Maltese citizenship therefore does not confer E-2 access.

Family inclusion (MPRP). Spouse or long-term partner; children of any age if unmarried and financially dependent; parents and grandparents of main applicant and spouse without an upper age limit, subject to dependency.

U.S. tax interaction. The U.S.–Malta income tax treaty signed in 2008 has been in force since 2010. Per the 21 December 2021 U.S.–Malta Competent Authority Arrangement, Maltese personal retirement schemes are not treated as "pension funds" under the treaty. Per IRS proposed regulations published 26 June 2023, certain Malta personal retirement schemes are identified as listed transactions. Publicly reported sources describe Maltese pension structuring and the Maltese 6/7 corporate-tax refund system as areas that have drawn IRS attention in matters involving U.S. persons and U.S.-owned Maltese companies. (General information, not tax advice — consult a U.S.-qualified CPA.)

Legislative stability. Very high volatility. The flagship citizenship route was abolished by binding EU court order in 2025; the residence program was substantially restructured by Legal Notice 146/2025 the same year.

Mobility. Maltese passport: approximately 184 visa-free destinations plus EEA + Switzerland. (MPRP holders do not receive a Maltese passport; they receive a Maltese residence card with Schengen visa-free travel under standard Schengen rules.)

For an American family. Until and unless Malta publishes a replacement citizenship route compatible with the CJEU judgment, Malta is effectively a residency-only proposition. For the residency itself, MPRP works and is well-administered, but the U.S.-specific tax friction (pension classification, corporate refund attention) reduces its U.S.-fit score.

5.3 Greece Golden Visa

The basics. Law 5100/2024, effective 31 August 2024, restructured Greece's Golden Visa into a two-zone system: - Zone A (Attica region, Thessaloniki regional unit, Mykonos, Santorini, and all islands with population > 3,100): minimum €800,000 in a single property of at least 120 m². - Zone B (the rest of Greece): minimum €400,000 in a single property of at least 120 m². - A special €250,000 option remains for conversion of commercial/industrial property to residential use, or restoration of a listed building.

All-in cost, family of 4. - Investment €400,000 (Zone B) or €800,000 (Zone A). - Government fees: €2,000 application + €150 per family member + €16 biometric and card fees per person — approximately €2,500 aggregate for a family of 4. - Transaction costs: property transfer tax 3.09%, notary ~1.5%, legal ~1–2% — approximately 6–8% of property price. - Legal/admin advisory ~€8,000–20,000. - All-in Zone B (€400K property): ~€430,000–445,000 (~$465,000–480,000). - All-in Zone A (€800K property): ~€855,000–870,000 (~$925,000–940,000).

Time to PR. The Golden Visa is a renewable 5-year residence permit granted on investment completion, typically processed in 2–6 months. Conversion to EU Long-Term Resident status requires 5 years of legal residence with substantive presence.

Time to citizenship. Naturalisation requires 7 years of lawful residence with substantive presence (generally 183+ days/year), Greek language and history exam, integration, and a clean record. Years of "zero presence" Golden Visa residence do not count. For a U.S. investor who actually relocates: 7+ years.

E-2 status. Greece has E-1 (treaty trader) status under a 1954 treaty but is not on the E-2 (treaty investor) list. Greek citizenship therefore does not unlock E-2 for U.S. business operation.

Family inclusion. Main applicant + spouse / registered partner (including same-sex civil partners) + dependent children under 21 (renewable to 24 if unmarried students) + parents of both the main applicant and the spouse, without an upper age limit or financial-dependency test. Often described as "three-generation" eligibility.

U.S. tax interaction. The U.S.–Greece income tax treaty was signed in 1950, making it among the oldest active U.S. tax treaties. It is narrow in scope, does not cover many modern items (capital gains, dividends treatment is limited; no LOB clause). Foreign tax credit is available, but treaty optimisation is materially weaker than under Portugal's or Italy's modern treaties. Greece's non-dom flat tax (Article 5A — €100,000/year flat on worldwide non-Greek income for 15 years) and 7% flat tax pension regime (Article 5B) are designed for non-U.S. persons; publicly reported tax practitioners note that the U.S. treaty's saving clause limits the pass-through of these benefits to U.S. citizens. (General information, not tax advice.)

Legislative stability. Moderate-to-high volatility: thresholds revised May 2023 (€250K → €500K in Attica/Thessaloniki/Mykonos/Santorini), restructured August 2024 (Law 5100, two-zone system + 120 m² minimum), transition deadline extended late 2024, anti-fraud documentation tightened in 2025. The program structure has been preserved across all three revisions.

Mobility. Greek passport: approximately 184 visa-free destinations plus EEA + Switzerland.

For an American family. Greece remains the lowest-cost route to a tangible EU residence card in Zone B at ~$465K all-in. The principal disadvantages from an American perspective are the absence of an E-2 treaty and the very old (1950) U.S. tax treaty, which together produce a weaker U.S.-fit profile than Portugal or Italy.

5.4 Italy Investor Visa

The basics. Italy's Investor Visa ("La Dolce Visa," administered through investorvisa.mise.gov.it) offers four tiers: - €250,000 in an Italian innovative startup. - €500,000 in an Italian limited company (Srl). - €2,000,000 in Italian government bonds. - €1,000,000 philanthropic donation to specified public-interest causes.

Investment thresholds have been stable since the 2020 Decreto Rilancio halving (which cut the €500K startup tier to €250K and the €1M bond tier to €500K, then later restored to €2M for bonds).

All-in cost, family of 4 (€250K startup tier). - Investment €250,000. - Government fees: D-visa ~€116/person + residence permit ~€200–300/person + e-card ~€30/person — aggregate ~€1,400–2,000 for family of 4 (ESTIMATE). - Legal + due diligence: ~€8,000–15,000 (market estimate). - All-in ~€260,000–270,000 (~$285,000–295,000).

Time to PR. Five years of legal continuous residence required for the permanent (long-term EU) residence permit under Italy's immigration code (T.U. 286/1998 art. 9). The initial Investor Visa grants a 2-year residence permit, renewable in 3-year increments while the investment is maintained.

Time to citizenship. 10 years of legal residence under Law 91/1992 article 9. Decree-Law 36/2025 (converted by Law 74/2025) tightened citizenship-by-descent rules; the residence-based naturalisation track for non-Italian-descent applicants — the relevant one for typical U.S. HNW families — is unchanged.

E-2 status. Yes, in force since 26 July 1949, without restrictive footnotes.

Family inclusion. Spouse, minor children under 18, and adult children dependent due to permanent disability. Dependent parents may be included under family reunification if the applicant proves financial support and the parent has no other supporting children in the home country (Italian immigration code art. 29).

U.S. tax interaction. The U.S.–Italy income tax treaty (signed 1999, in force after the 2009 Protocol) is in effect. Saving clause preserves U.S. worldwide taxation. CFC, GILTI, PFIC, and FATCA all apply. Italy operates a flat-tax regime for new tax residents: a lump-sum €200,000/year on foreign income (raised from €100,000 by Decree-Law 113/2024 for new opters after 10 August 2024). Publicly reported tax practitioners observe that, while the Italian flat-tax regime is attractive to many non-U.S. HNW residents, U.S. worldwide taxation through the saving clause limits the net benefit available to U.S. citizens. (General information, not tax advice.)

Legislative stability. Stable on the investor visa itself: investment thresholds unchanged since the 2020 Decreto Rilancio halving. The main 2023–2026 program-side changes were administrative (suspension of Russian-national applications in July 2023; extension to Russian/Belarusian dual nationals in March 2024) and tax-side (flat-tax lump sum doubled August 2024). The major citizenship-by-descent restriction of March–May 2025 affects descent claims, not the Investor Visa.

Mobility. Italian passport: approximately 185 visa-free destinations plus EU freedom of movement across 27 member states.

For an American family. Italy is the lowest-cost EU option with an active E-2 treaty and a modern U.S. tax treaty. The 10-year naturalisation horizon is long, but the program structure has been the most stable in Europe over the last three years, and the entry-point cost is materially lower than Portugal's Golden Visa.

5.5 Cyprus Permanent Residency by Investment

The basics. Cyprus offers a fast-track Permanent Residency under Regulation 6(2) — a permit issued for life provided the underlying investment is maintained and annual compliance is met.

All-in cost, family of 4. - Investment: €300,000 + 19% VAT (or 5% on a primary residence under conditions) in newly-built residential real estate, or commercial real estate, or Cyprus-registered company shares, or collective-fund units. - Government fees: €500/applicant — ~€2,000 for family of 4. - Annual income threshold (hard gate, not a fee): €50,000 main applicant + €15,000 spouse + €10,000/dependent child. - Legal + due diligence: ~€5,000–12,000 (ESTIMATE). - All-in family of 4 (real estate, 19% VAT): ~€380,000 (~$415,000). - All-in with 5% reduced VAT on primary residence: ~€345,000.

Time to PR. Approximately 2–3 months from complete filing — the fastest of the nine programs. The permit is permanent (lifelong), conditional on maintaining the investment and meeting the annual compliance requirements introduced in May 2023.

Time to citizenship. 7 years of legal residence within the preceding 10-year window, with the final 12 months continuous immediately before application. A 4–5-year accelerated route exists for "highly skilled" workers with Greek-language B1 proficiency (in force since 19 December 2023) — it does not apply to passive investors. Greek B1 plus a civics exam (≥60%) are required.

E-2 status. No. A Cypriot passport does not confer E-2 eligibility.

Family inclusion (post-May 2023 reform). Spouse + minor children under 18. Unmarried children aged 18–25 in higher education abroad who are financially dependent must file separately and require an additional €10,000/year per such child. Parents and parents-in-law are excluded (removed by the May 2023 reform — a material narrowing). Adult non-dependent children require multiplication of the €300K investment threshold.

U.S. tax interaction. A U.S.–Cyprus income tax treaty has been in force since 1985. Standard saving clause. Cyprus's non-dom regime (no tax on dividends or foreign-source income for non-doms for 17 years) is structured for non-U.S. passport holders; publicly reported tax practitioners note that the U.S. treaty saving clause limits its benefit to U.S. citizens. (General information, not tax advice.) FATCA Model 1 IGA is in force; full reporting.

Legislative stability. Moderate. The principal 2023 reform raised the annual foreign-income threshold from €30K to €50K, removed parents from eligible dependents, and introduced an annual compliance attestation. No further material changes on the PR-by-investment regulation 2024–2026.

Mobility. Cypriot passport: approximately 174 visa-free destinations plus full EU freedom of movement.

For an American family. Cyprus offers the fastest pathway to a tangible EU PR (2–3 months) at moderate cost, but the lack of E-2 access, the 7-year citizenship horizon with a Greek-language B1 requirement, and the narrower 2023 family-inclusion rules reduce its appeal for the typical American HNW family profile.

5.6 New Zealand Active Investor Plus (AIP+)

The basics. New Zealand's AIP+ was substantially restructured on 1 April 2025 after the prior 2022 regime received only ~9 applications by January 2024. The 2025 relaunch removed English-language requirements, eliminated investment caps, added newborn dependent coverage, and admitted bonds and certain property investments. Two tiers: - Growth category: NZD 5,000,000 minimum (direct + managed-fund NZ investments) over 3 years. - Balanced category: NZD 10,000,000 minimum (broader portfolio including bonds, listed equities, philanthropy, and now property development) over 5 years.

All-in cost, family of 4. - Investment: NZD 5M (Growth) or NZD 10M (Balanced). - Government fees: "from NZD 27,470" per Immigration NZ schedule (family inclusion; varies). - Legal + due diligence: NZD 30,000–80,000 typical (ESTIMATE). - All-in Growth: ~NZD 5,070,000 ≈ USD 3,050,000. - All-in Balanced: ~NZD 10,070,000 ≈ USD 6,050,000.

Time to PR. Resident visa granted at approval-in-principle, after funds are committed. Approval-in-principle: 80% within 3.5 months. Upgrade to Permanent Resident Visa available after the investment term (3 years Growth / 5 years Balanced) and minimum physical presence (21 days Growth / 105 days Balanced over the term).

Time to citizenship. 5 years as a resident with physical presence of ≥1,350 days total AND ≥240 days in each of the 5 years. English language requirement plus good-character and an oath ceremony. From mid-2027, a formal citizenship test will be required. The AIP+ minimum physical presence (21 or 105 days) is far below the citizenship physical-presence test. Naturalisation through AIP+ realistically requires actual relocation, not nominal residency.

E-2 status. Yes, in force since 10 June 2019. New Zealand citizenship opens E-2 access — relevant for an American family planning a long horizon.

Family inclusion. Partner (genuine relationship of ≥12 months) and dependent children up to age 24 (21–24 must prove dependence). Newborns of investors granted dependent child resident visas (added in the April 2025 reform). Parents are not included as dependents.

U.S. tax interaction. U.S.–New Zealand income tax treaty (1982; amended by 2008 Protocol, in force November 2010). Standard saving clause — U.S. citizens remain taxable worldwide. Publicly reported sources describe New Zealand's Foreign Investment Fund (FIF) rules as overlapping with U.S. PFIC rules for U.S. citizens who become NZ tax residents, an area practitioners report as administratively complex. The NZ transitional resident exemption (up to 4 years on foreign-source income) is described in public guidance as a temporary mitigation. (General information, not tax advice — consult a U.S.-qualified CPA.)

Legislative stability. Investor-favorable volatility. The 2025 relaunch substantially improved the program; subsequent tweaks (a June 2025 25% cap on cash/term deposits within investment portfolios) have refined rather than redirected it. As of May 2026, INZ reports 688 applications under the new settings covering 2,260 individuals, with 568 approved in principle — a strong uptake signal compared to the prior regime's ~9.

Mobility. New Zealand passport: approximately 182 visa-free destinations. Six-month visa-free stay in the UK, 90 days in Schengen, U.S. ESTA-eligible.

For an American family. Highest absolute cost (USD 3M–6M+) and the slowest realistic path to citizenship (which effectively requires real relocation). But the only program in our top tier where the resulting passport unlocks new E-2 access for an American spouse or child holding only the NZ passport. Strong rule-of-law and political-stability characteristics.

5.7 Cayman Islands — Certificate of Permanent Residence (R42)

The basics. Cayman's R42 Certificate of Permanent Residence for Persons of Independent Means is governed by the Immigration (Transition) Act and the Immigration Regulations (2025 Revision), administered by WORC (Workforce Opportunities and Residency Cayman).

All-in cost, family of 4 (USD). - Investment: KYD 2,000,000 (~ USD 2,400,000) in developed real estate, held for the life of the certificate. - Government issuance fee: KYD 100,000 (~ USD 120,000) upon grant + KYD 1,000 (~ USD 1,200) per approved dependant. Application fee KYD 500 (~ USD 600). - Stamp duty on real estate purchase: 7.5% of property value. On USD 2.4M property: ~USD 180,000. - Legal + due diligence: USD 30,000–60,000 (ESTIMATE). - Total non-recoverable fees for family of 4: ~USD 330,000–360,000. Plus USD 2.4M in tied real estate (asset retained).

Time to PR. Direct-to-PR (no temporary stage). 3–9 months once documentation is complete. Indefinite validity.

Time to citizenship. Cayman is a British Overseas Territory; no Cayman citizenship exists. After 5 years of legal residence and meeting character requirements, a holder may apply for Caymanian Status (limited annual Cabinet quota, typically 4 grants/year, plus a separate Status Board process), and after a further 5 years for British Overseas Territories Citizenship (BOTC) under the British Nationality Act 1981. BOTC holders may register as British citizens.

E-2 status. No. Although the UK is on the E-2 list, the U.S. State Department explicitly states that the treaty "applies only to British territory in Europe (the British Isles except the Republic of Ireland, the Channel Islands and Gibraltar)." British Overseas Territories — including the Cayman Islands — are excluded.

Family inclusion. Spouse and dependent children under 18 (or under 24 in full-time tertiary education) included on the main application; KYD 1,000 grant fee per dependant. Parents/siblings are not automatically included.

U.S. tax interaction. No U.S.–Cayman income tax treaty. Cayman levies no income, capital gains, inheritance, or corporate tax. A FATCA Model 1B IGA has been in force since 2013 (amended subsequently); Cayman financial institutions report U.S. accountholder data to the Cayman Tax Information Authority, which transmits to the IRS. Per publicly available IRS guidance, U.S. citizens remain subject to U.S. worldwide taxation regardless of foreign residence, and FBAR / Form 8938 reporting thresholds apply by their terms. Publicly reported practitioners observe that foreign residence does not by itself reduce U.S. federal tax liability for U.S. citizens, and that state-level tax outcomes depend on whether U.S. state residency is severed under the relevant state's rules. (General information, not tax advice.)

Legislative stability. Stable on the R42 investment threshold (unchanged since the 2013 Regulations). Adjacent volatility on the PR-by-residence track (March 2023 Court of Appeal ruling; April 2025 Privy Council reversal) does not affect R42.

Mobility. R42 does not confer a passport. The eventual BOTC route, if completed, leads to a British Citizen passport with approximately 183 visa-free destinations.

For an American family. The most capital-intensive program in this set, with no E-2 path and no near-horizon naturalisation. The case for Cayman is generally not "second passport on a defined timeline" but "premium PR in a no-direct-tax jurisdiction with strong banking and rule-of-law characteristics."

5.8 Panama Qualified Investor Visa

The basics. Panama's Qualified Investor route, administered by the Servicio Nacional de Migración, was created by Executive Decree 722/2020 and amended by Decree 109/2022, Decree 193/2024, and Law 493/2025. The real-estate threshold was reduced from USD 500,000 to USD 300,000 in 2024 — a temporary reduction. Per Decree 193/2024, the threshold is scheduled to revert to USD 500,000 after October 2026.

All-in cost, family of 4 (USD). - Investment: USD 300,000 in registered real estate, no mortgage, held throughout residency. (Set to revert to USD 500,000 after October 2026.) - Government fees: USD 5,000 SNM application + USD 1,000 Treasury per applicant + ~USD 2,000–3,000 dependant fees for family of 4. - Real estate transfer tax: 2% — USD 6,000 on USD 300,000. - Legal + due diligence: USD 15,000–25,000 (ESTIMATE). - Total non-recoverable fees for family of 4: ~USD 30,000–45,000. Plus USD 300,000 in tied real-estate capital (asset retained).

Time to PR. Direct-to-PR. Target 30 business days from a complete file; in practice 2–6 months.

Time to citizenship. 5 years of legal permanent residence required to apply (Article 10 of the Panamanian Constitution). Reduced to 3 years if married to a Panamanian or with a Panamanian-born child. Spanish-language test, civics test, clean record. Naturalisation is discretionary and typically takes 2–5 additional years in practice. Note: Law 493 of 28 October 2025 introduced a "Special Travel Passport" for Qualified Investors and dependants — a Panamanian travel document but not equivalent to full citizenship.

E-2 status. Yes, in force since 30 May 1991. A naturalised Panamanian (5+ years) can apply for an E-2 investor visa to the U.S.

Family inclusion. Spouse, dependent children under 18 (under 25 if proven full-time student and financially dependent), parents of the principal applicant if financially dependent, and dependants with disabilities.

U.S. tax interaction. No U.S.–Panama income tax treaty. Panama operates a territorial tax system — only Panama-source income is taxable in Panama; foreign-source income (U.S. salary, U.S. dividends, capital gains on U.S. assets) is exempt from Panamanian tax. A U.S.–Panama Tax Information Exchange Agreement (TIEA) has been in force since 18 April 2011. A FATCA Model 1 IGA was signed 27 April 2016. Per publicly available IRS guidance, U.S. citizens remain subject to U.S. worldwide taxation. Publicly reported practitioners note that Panama residence does not by itself reduce U.S. federal liability absent expatriation, and that the Foreign Earned Income Exclusion (IRC §911) is described in IRS publications as potentially available against qualifying foreign earned income, subject to its statutory requirements. (General information, not tax advice.)

Legislative stability. Moderate volatility. Frequent legislative tweaks (Decree 109/2022, Decree 193/2024, the August 2025 Ministry strategy review, Law 493/2025). The trajectory is upward in cost — the USD 300,000 threshold is scheduled to revert to USD 500,000 after October 2026. Families seeking the lower threshold should plan to act before that change.

Mobility. Panamanian passport: approximately 147 visa-free destinations. Includes Schengen (90/180), the UK, Russia, and most of Latin America. Does not include the United States itself — Panama is an E-2 country, but a Panamanian still requires a B1/B2 visa for U.S. travel purposes separate from E-2 business activities.

For an American family. The cheapest entry in the E-2-bearing group at roughly USD 335K, and the only Latin American option in this report with an active E-2 treaty plus a defined 5-year naturalisation track. The principal disadvantages are the legislative volatility (cost is set to rise) and the absence of a U.S. income tax treaty.

5.9 Anguilla — ARBI and HVR

The basics. Anguilla, a British Overseas Territory, offers two distinct tracks administered by the Ministry of Finance: - ARBI (Anguilla Residency by Investment) — leads to permanent residency. - HVR (High Value Resident) — a tax-residency status.

Track A — ARBI (PR) cost, family of 4 (USD). - Real-estate option: USD 750,000 minimum in approved real estate, held 5 years (+USD 100,000 per dependant beyond a family of 4). - Capital Development Fund (donation) option: USD 150,000 contribution for a family of up to 4 (+USD 50,000 per additional dependant). - Processing fee: USD 3,000 family of 4 (+USD 500 per additional dependant). - Due diligence: USD 7,500 per applicant aged 18+; USD 2,500 per dependant aged 12–17; under 12 free. - Legal + admin: USD 15,000–25,000 (ESTIMATE). - All-in donation route: ~USD 195,000–210,000 non-recoverable. - All-in real-estate route: ~USD 50,000–60,000 non-recoverable fees + USD 750,000 real-estate capital (recoverable after 5 years).

Track B — HVR (tax residency) cost, family of 4. - Annual lump-sum tax: USD 75,000 on worldwide income (flat), with a requirement to demonstrate 5-year prepay capacity (USD 375,000 escrow demonstration). - Property: USD 400,000 minimum, continuously held. - Processing + DD as ARBI. - Year 1 cash outflow for family of 4: USD 75,000 + ~USD 30,000–45,000 fees and legal = ~USD 105,000–120,000, plus USD 400,000 property.

Time to PR. ARBI: ~3–6 months from complete file. HVR: ~3 months (tax-residency permit, renewable annually).

Time to citizenship. Anguilla is a UK Overseas Territory; no Anguillian citizenship exists. The route is to British Overseas Territories Citizenship (BOTC) after legal residence (commonly cited as 5 years with substantial physical presence — typically not absent more than 450 days in the 5-year period). BOTC holders may then register as British citizens under the British Nationality Act 1981. ARBI alone does not satisfy the presence requirement — actual physical residence in Anguilla is required for BOTC naturalisation.

E-2 status. No. Same UK geographic limitation: British Overseas Territories are excluded.

Family inclusion (ARBI). Spouse, dependent children under 18, children 18–26 in full-time tertiary education or on a "gap year" (per 2024 amendments) / not continuously enrolled; dependent parents and grandparents of principal and spouse over 65 who reside with the family.

U.S. tax interaction. No U.S.–Anguilla income tax treaty. Anguilla levies no personal income tax, no capital gains tax, no inheritance tax, no corporate income tax. A FATCA Model 1 IGA is in force; Anguilla appears on the IRS FATCA jurisdictions list. Per publicly available IRS guidance, U.S. citizens remain subject to U.S. worldwide taxation regardless of Anguillian residence. Publicly reported practitioners note that Anguilla's HVR USD 75,000 flat tax is generally not creditable against U.S.-source income under standard foreign-tax-credit principles, and that HVR's reported utility for U.S. persons is often described as non-tax in nature (privacy, lifestyle, U.S. state-residency severance). (General information, not tax advice.)

Legislative stability. The most stable of the three Caribbean / UK Overseas Territory programs in this report over the 36-month window. The Anguilla Economic Residence (Approved Real Estate) Regulations 2024 formalised property qualification rules and modestly expanded dependant categories — all investor-favorable amendments. The HVR USD 75,000 flat tax has not been publicly increased in the window. A structural caveat: as a UK Overseas Territory, Anguilla is subject to UK FCDO scrutiny of CBI/RBI programs; the EU listed Anguilla on its tax non-cooperative jurisdictions list in 2021 and removed it in October 2022.

Mobility. ARBI/HVR do not confer a passport. BOTC and onward British citizenship (after the long route) would provide approximately 183 visa-free destinations.

For an American family. The lowest-cost program in the bottom half of our ranking and the most stable in regulatory terms. The principal limitations are the absence of an E-2 treaty, the absence of a near-term passport upgrade, and the fact that — like Cayman — Anguilla cannot reduce U.S. federal tax liability for a U.S. citizen who retains U.S. nationality.

6. Cross-cutting observations

Three patterns emerge across the nine programs that we believe are worth surfacing explicitly.

(a) The E-2 question is doing more work than its share of the conversation suggests. Only four of the nine programs lead to a citizenship in a country with an active E-2 treaty with the United States: Portugal, Italy, New Zealand, and Panama. For a family whose long-horizon question is "what door does this open back to the U.S. for my children if they hold only this passport?", this single yes/no fact filters the answer set down to four programs immediately. The five remaining programs — Malta, Greece, Cyprus, Cayman, and Anguilla — have other merits, but they cannot answer the E-2 question regardless of how much money is spent.

(b) The 36-month legislative trend is toward longer timelines and tighter scrutiny. Portugal doubled its residence-to-citizenship clock from 5 to 10 years (May 2026). Malta's MEIN was struck down by the Court of Justice of the European Union (April 2025). Cyprus's 2023 reform removed parents from eligible dependents and raised the foreign-income threshold. The IRS has explicitly flagged Maltese pension schemes as listed transactions (June 2023). The direction of travel is uniformly toward "more rigour, more time, more money." This is relevant for an American family because the assumption that "next year will be like this year" is unsupported by the data; programs that look attractive on current rules may be materially less attractive on the rules in force at the time the family would actually use them.

(c) The U.S. tax overlay dominates the planning math, not the foreign program. Every program in this set leaves U.S. worldwide taxation in place for U.S. citizens. The foreign-side flat-tax regimes that have driven the wave of European applications since 2020 — Portugal NHR (closed), Italy €200K lump-sum, Greece Article 5A/5B, Cyprus non-dom 17-year — provide most of their benefit to non-U.S. passport holders. In Truvon's editorial view, publicly reported U.S.-qualified practitioners more often frame the analysis around which jurisdiction is least likely to add incremental U.S. tax exposure or reporting burden, rather than which jurisdiction has the headline-friendliest local tax regime. On that framing, countries with modern, well-tested U.S. tax treaties (Portugal 1994, Italy 1999/2009, New Zealand 1982/2010, Malta 2008) tend to be described differently from those without (Cayman, Panama, Anguilla) or with very old narrow treaties (Greece 1950). (Editorial commentary, not tax advice.)

(d) None of these programs is about leaving. They are about expanding the set of doors a family can open. The American families considering them are not escaping the United States; they are refusing to accept that the country they hold a passport in should be the only country in which they have a stake. That distinction matters because it determines what success looks like. A family that gets the residency right but uses it as an exit is making a different choice from a family that gets the residency right and uses it as an option held in reserve. Public reporting and survey commentary from advisors suggests that most American HNW families exploring these programs in 2026 frame the decision as an option held in reserve rather than as an exit. This report is written as editorial commentary for that audience.

7. What this report does NOT include

The following topics are outside the editorial scope of this v1 report. Their absence is not a comment on their importance to any reader's situation; readers requiring analysis of these topics should engage licensed counsel.

• Caribbean Citizenship-by-Investment (St. Kitts, Dominica, Grenada, Antigua, St. Lucia). Each has features that would meaningfully change the ranking on speed, cost, and (for Grenada specifically) E-2 status. A future companion brief is planned. Grenada in particular is the only Caribbean CBI country with an active E-2 treaty and warrants standalone analysis.
• Tax-treaty optimization scenarios (LOB clause interactions, hybrid entity treatment, structured wealth holding). These are individual planning questions and not generalisable in a report.
• State-level U.S. residency-severance planning. Many American families' largest single tax saving from moving abroad is at the state level (California, New York). This requires specific state-by-state analysis and is omitted here.
• Real-estate market analysis in any of the destination countries. We did not assess whether the qualifying real-estate purchases described above are good investments in themselves; we treated them as the cost of the program.
• Healthcare, schooling, and lifestyle comparisons. These are decisive in any actual decision but are outside the scope of a residency-and-citizenship comparison.

8. How to read the score (and disagree with it)

The Plan B Readiness Score is Truvon's opinion-based composite. We have written it down rather than kept it informal because we believe a published score forces the analyst to be explicit about trade-offs. A reader who disagrees with our weights — for example, a reader who weights mobility more highly than U.S.-tax fit — can re-weight the same axis scores and produce a different ranking. The axis scores themselves are the load-bearing part of the analysis; the composite is the wrapper.

We have deliberately not compared visa-free destination counts using any commercial passport index. The figures in this report come from publicly aggregated bilateral visa agreements (commonly accessible via Wikipedia's Visa requirements for [country] citizens pages, which in turn cite each country's ministry of foreign affairs). This is an intentional choice: the underlying data — bilateral agreements between governments — is public and not the property of any commercial ranker.

9. About Truvon Global Citizenship

Truvon Global Citizenship is an independent media and analysis publisher focused on residency and citizenship topics of interest to American HNW audiences. Truvon is not a licensed legal, immigration, tax, or investment advisor in any jurisdiction. Truvon does not handle client investment funds. Truvon is not an authorized agent of any program described in this report and receives no commission, referral fee, or other compensation from any program operator or service provider in connection with this report. Truvon's separate professional service engagements with clients (including document preparation and application coordination) are governed by separate written engagement letters and are not constituted, offered, or solicited by this report. Truvon's role in this report is editorial and educational; any actual program application must be executed by licensed counsel separately engaged by the reader in the relevant jurisdiction.

For questions about this report, please use the contact channels on truvonglobal.com.

10. Update cadence and revisions

This is version 1 (May 2026). We expect to revise as follows:

• Material legislative change in any covered program: notice within 30 days of publication of the change.
• Annual full revision: 12 months from publication of this v1.
• Errata: corrections logged at the end of the report with date and reason.

11. Sources

All facts in this report are sourced from one of the following categories. Specific source URLs appear inline in Section 5 for each program; here we list the categories.

Official program sites and government gazettes: - Agência para a Integração, Migrações e Asilo (AIMA), Portugal - Investorvisa.mise.gov.it (Italy Investor Visa) - Greek Ministry of Migration & Asylum - Residency Malta Agency; Government of Malta press releases - Cyprus Civil Registry & Migration Department - Immigration New Zealand (immigration.govt.nz) - WORC / Cayman Government (gov.ky) - Servicio Nacional de Migración, Panama (migracion.gob.pa) - Government of Anguilla, Ministry of Finance (gov.ai); Anguilla Inland Revenue Department

U.S. federal agencies: - U.S. Department of State, Treaty Countries — travel.state.gov - U.S. Citizenship and Immigration Services (USCIS) — uscis.gov - Internal Revenue Service — irs.gov (tax treaty documents, listed-transactions page, Competent Authority Arrangements) - U.S. Department of the Treasury — home.treasury.gov (FATCA IGAs and TIEAs)

EU and international bodies: - Court of Justice of the European Union (CJEU) — eur-lex.europa.eu and curia.europa.eu - Investment Migration Council (IMC) — investmentmigration.org (regulatory body, not a consultancy) - OECD, World Bank, UN (background macro)

Major neutral media (cited for context and event-confirmation, not for primary facts): - Bloomberg, Reuters, Financial Times, Wall Street Journal, BBC, Associated Press - The Portugal News (event coverage), Cyprus Mail (event coverage), Cayman Compass (event coverage)

Big Four / major accounting firms (cited for neutral technical analysis): - PwC, KPMG, Deloitte, EY — global mobility services flash alerts and tax bulletins

Mobility data: - Wikipedia "Visa requirements for [country] citizens" pages — used as an aggregator of public bilateral agreements; the underlying data is each country's ministry of foreign affairs.

This report does not cite any commercial citizenship-by-investment or residency-by-investment consultancy or rank by any commercial passport index.