Why Americans are Not Moving Their Wealth Offshore (2025)

No, Most Wealthy Americans are Not Fleeing the U.S.

Why Americans are Not Moving Their Wealth Offshore

Contrary to what online offshore/expat marketers and salespersons want you to believe, droves of high-net-worth (HNW) Americans and other wealthy U.S. Citizens are not high-tailing it out of the United States to move to less developed countries to invest millions of dollars into volatile and unproven markets in countries with unstable governments — all in the hopes of avoiding U.S. taxes. Contrary to what these marketers want you to believe, the United States is still the top destination for wealthy Americans — and where HNW foreigners seek to relocate.

Wealthy Americans and Expats Still Choose the U.S.

Despite all the static you will find online from professional marketers who want you to believe that wealthy taxpayers are fleeing the United States — the opposite is true. Wealthy expats from across the globe are still vying for an opportunity to become U.S. permanent residents and ultimately U.S. citizens. That is why there is such a backlog of visa applications including the EB-5 visa — which is the U.S. investment visa that foreigners use to obtain permanent residency and ultimately become U.S. citizens.

What is the Source of the Information?

Most people online trying to convince you to pay 6-figures for some outdated, ineffective boilerplate strategy to go offshore are non-tax, non-legal salespersons slickly marketing their services. The only way they make money is by convincing you, the unsuspecting American, to pay them hundreds of thousands of dollars for the opportunity to invest millions of dollars offshore by making you believe ‘everyone’ is doing it — which is simply not true. Let’s briefly examine why the United States is still the premier country for wealthy American and non-American taxpayers.

Free Market

In the United States, almost anyone, anywhere can purchase an asset that is available on the open market.

Let’s take a common example: There are rarely any restrictions for purchasing real estate in the United States. If a taxpayer has the money to buy a property that is for sale, the taxpayer can purchase that property.  It does not matter if the buyer is a U.S. person or not. And, while the tax rules are different for U.S. persons and non-U.S. persons, the buyer does not have to be a U.S. person to acquire property. In many foreign countries, there is a requirement that the taxpayer either live in that country or be a citizen of that country to acquire property.  And since nothing is more valuable than time, having to sit back for one or more years waiting to buy an asset that could increase in value infinitely is not alluring to most wealthy taxpayers — which is why they choose to move to the United States and become U.S. persons.

Stable Government

The U.S. government is relatively stable. And while the political pendulum swings both ways (depending on what political side you are on, you will either be more happy or less happy with the outcome of any election) there are still checks and balances in place. This gives wealthy taxpayers peace of mind, especially when they invest large amounts of money into assets located in the United States.

Strong Passport

The United States passport is still strong. It may not technically be the ‘strongest passport’ — but it still provides Americans with endless opportunities to travel the globe — noting, that whether a passport is strong or not is a gray area and dependent on several factors. It is also very important to remember that many of the different companies that like to rate passports have an ulterior motive — which is that they are selling (or acting as the middleman) golden visas to countries that they rank higher than the United States. 

Healthcare, Education, and More

Wealthy Americans and non-Americans who live in the United States have access to some of the best physicians globally. Likewise, and especially for Americans and non-Americans living in the United States with children, the United States has countless different universities and other educational opportunities that make it a premier location for wealthy Americans and expats who have children or want to continue their education.

Always Beware of the Source of Your ‘Offshore’ Information

It is very easy for a marketer to go online, prepare some glossy materials, and try to sell taxpayers on this idea of going offshore with an ‘Offshore Plan B‘ because everyone is doing it. It is easy to make that statement without having to prove anything.  The reality is that most wealthy Americans are very happy and thriving in the United States and prefer to live in the United States just as many foreign expats across the globe prefer to move their family to the United States and will take any opportunity they can to make that dream happen.

Late-Filing Disclosure Options

Oftentimes, the catalyst for going offshore is the fear of being non-compliant with U.S. tax and reporting. If a Taxpayer is out of compliance, there are various international offshore tax amnesty programs that they can apply to safely get into compliance. Depending on the specific facts and circumstances of the Taxpayers’ noncompliance, they can determine which program will work best for them.

*Below please find separate links to each program with extensive details about the reporting requirements and examples.

Streamlined Filing Compliance Procedures (SFCP, Non-Willful)

The Streamlined Filing Compliance Procedures is one of the most common programs used by Taxpayers who are non-willful and qualify for either the Streamlined Domestic Offshore Procedures or Streamlined Foreign Offshore Procedures.

Streamlined Domestic Offshore Procedures (SDOP, Non-Willful)

Taxpayers who are considered U.S. residents and file timely tax returns each year but fail to report foreign income and/or assets may consider the Streamlined Domestic Offshore Procedures.

Streamlined Foreign Offshore Procedures (SFOP, Non-Willful)

Taxpayers who are foreign residents may consider the Streamlined Foreign Offshore Procedures which is typically the preferred program of the two streamlined procedures. That is because under this program Taxpayers can file original returns and the 5% title 26 miscellaneous offshore penalty is waived.

Delinquent FBAR Submission Procedures (DFSP, Non-Willful/Reasonable Cause)

Taxpayers who only missed the FBAR reporting and do not have any unreported income or other international information reporting forms to file may consider the Delinquent FBAR Submission Procedures — which may include a penalty waiver.

Delinquent International Information Returns Submission Procedures (DIIRSP, Reasonable Cause)

Taxpayers who have undisclosed foreign accounts and assets beyond just the FBAR — but have no unreported income — may consider the Delinquent International Information Return Submission Procedures. Before November 2020, the IRS was more inclined to issue a penalty waiver, but since then this type of delinquency procedure submission has morphed into a reasonable cause request to waive or abate penalties.

IRS Voluntary Disclosure Procedures (VDP, Willful)

For Taxpayers who are considered willful, the IRS offers a separate program referred to as the IRS Voluntary Disclosure Program (VDP). This program is used by Taxpayers to disclose both unreported domestic and offshore assets and income (before 2018, there was a separate program that only dealt with offshore assets (OVDP), but that program merged back into the traditional voluntary disclosure program (VDP).

Quiet Disclosure

Quiet disclosure is when a Taxpayer submits information to the IRS regarding the undisclosed foreign accounts, assets, and income but they do not go through one of the approved offshore disclosure programs. This is illegal and the IRS has indicated they have every intention of investigating Taxpayers who they discover intentionally sought to file delinquent forms to avoid the penalty instead of submitting to one of the approved methods identified above.

Late Filing Penalties May be Reduced or Avoided

For Taxpayers who did not timely file their FBAR and/or other international information-related reporting forms, the IRS has developed many different offshore amnesty programs to assist Taxpayers with safely getting into compliance. These programs may reduce or even eliminate international reporting penalties.

Current Year vs. Prior Year Non-Compliance

Once a Taxpayer missed the tax and reporting (such as FBAR and FATCA) requirements for prior years, they will want to be careful before submitting their information to the IRS in the current year. That is because they may risk making a quiet disclosure if they just begin filing forward in the current year and/or mass filing previous year forms without doing so under one of the approved IRS offshore submission procedures. Before filing prior untimely foreign reporting forms, Taxpayers should consider speaking with a Board-Certified Tax Law Specialist who specializes exclusively in these types of offshore disclosure matters.

Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)

In recent years, the IRS has increased the level of scrutiny for certain streamlined procedure submissions. When a person is non-willful, they have an excellent chance of making a successful submission to Streamlined Procedures. If they are willful, they would submit to the IRS Voluntary Disclosure Program instead. But, if a willful Taxpayer submits an intentionally false narrative under the Streamlined Procedures (and gets caught), they may become subject to significant fines and penalties. 

Need Help Finding an Experienced Offshore Tax Attorney?

When it comes to hiring an experienced international tax attorney to represent you for unreported foreign and offshore account reporting, it can become overwhelming for Taxpayers trying to trek through all the false information and nonsense they will find in their online research. There are only a handful of attorneys worldwide who are Board-Certified Tax Specialists and who specialize exclusively in offshore disclosure and international tax amnesty reporting. 

*This resource may help Taxpayers seeking to hire offshore tax counsel: How to Hire an Offshore Disclosure Lawyer.

Golding & Golding: About Our International Tax Law Firm

Golding & Golding specializes exclusively in international tax, specifically IRS offshore disclosure. 

Contact our firm today for assistance.