Buying in: Residence and Citizenship by Investment

22 Pages Posted: 28 Sep 2017

Date Written: September 26, 2017


States have complex and often conflicted attitudes toward migration and citizenship. These attitudes are not always directly expressed by lawmakers, but they may be reflected quite explicitly in tax regimes: for the world’s most prosperous individuals and their families, multiple states extend a warm welcome. Sometimes prospective migrants are offered fast track to physical residence which can lead to citizenship if the migrant desires it. Others are offered a mere commercial transaction, with citizenship granted to applicants with the right credentials and a willingness to pay. Migrants might seek to obtain residency or citizenship for personal, family, economic, or tax reasons, or some combination of them. For the granting country, the tax significance of obtaining new residents or citizens will vary depending on domestic policy goals. However, the consequences of residence and citizenship by investment programs could be severe for the international tax regime: the jurisdiction to tax and the allocation of taxing rights among countries are commonly based on residence and citizenship factors. This article accordingly surveys contemporary residence and citizenship by investment programs on offer around the world and analyzes their potential impact on international tax policy.

Keywords: Taxation, Tax Policy, Migration, Investment, Citizenship, Nationality, Residence, Immigrant Investor Programs, Golden Visa, Economic Citizenship, Financial Citizenship, Common Reporting Standard

JEL Classification: D78, F02, F22, F42, H20, H26, H87, K33, K34

Suggested Citation

Christians, Allison, Buying in: Residence and Citizenship by Investment (September 26, 2017). St. Louis University Law Journal, Forthcoming, Available at SSRN:

Allison Christians (Contact Author)

McGill University - Faculty of Law ( email )

3644 Peel Street
Montreal H3A 1W9, Quebec

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