Golden Visa and residency for US citizens: the American's guide to Portugal, Malta, Greece and the Caribbean (2026)

My Golden Visa's own client conversations with US-based applicants point to three recurring drivers, not one. Some are building a political and economic hedge: uncertainty at home has pushed clients to describe a second residence explicitly as a "plan B," a place to land if the situation changes. Others are optimizing a financial and lifestyle position they already have: retirees moving retirement savings through a self-directed IRA rollover, or families who want a base with good healthcare and schooling without giving up their US income. A third group is acting on family mobility: getting a spouse, children or aging parents into a stable jurisdiction while everyone still qualifies as a dependant.

Each motivation points toward a different kind of route. A hedge-driven applicant who never plans to relocate is usually better served by citizenship by investment or a low-presence residence route, since they want the document, not the daily life. A lifestyle-driven applicant is usually better served by a European residence route with a real path to long-term settlement. A family-driven applicant needs to check dependant rules (spouse, children, parents) before anything else, because eligibility windows close as children age out.

Every other nationality asks "what does this residence or citizenship give me?" A US citizen has to ask a second question first: "what does it not change with the IRS?"

A US citizen or US permanent resident remains subject to US tax on worldwide income for as long as they hold that status, regardless of where they live or which other residence or citizenship they hold. Moving to Portugal, Greece or Malta, or obtaining a Caribbean citizenship, does not end this obligation. Only relinquishing US citizenship (or, for a green card holder, formally abandoning permanent residence) changes it, and that is a separate, irrevocable legal step most applicants are not pursuing.

Three reporting layers commonly surprise clients who assumed residence abroad would simplify their filing:

• Foreign bank and financial accounts. A US person with foreign financial accounts generally has an annual FBAR filing duty (FinCEN Form 114) once account balances cross the reporting threshold, separate from the income tax return itself.
• FATCA reporting on foreign assets. Under the Foreign Account Tax Compliance Act, US persons holding foreign financial assets above the applicable threshold report them to the IRS, and most foreign banks and fund administrators separately report US account holders to the IRS under FATCA's institutional rules.
• PFIC exposure on non-US investment funds. This is the one that catches European Golden Visa applicants specifically. Many of the qualifying investment funds used for the Portugal and Greece residence routes are non-US pooled vehicles. For a US person, a non-US fund is typically a passive foreign investment company (PFIC), which brings annual Form 8621 filing and a default tax treatment on gains and distributions that is considerably harsher than US capital gains rates unless specific elections are made in time.

None of this means a US citizen should avoid these programs. It means the fund or investment route has to be screened for PFIC exposure before money moves, and a US-qualified cross-border tax adviser should be part of the team from the start, not brought in after the investment is made. Get the reporting mechanics right and confirm your own filing thresholds with a US tax adviser and the IRS before committing capital; this guide explains what each route requires, not what your personal return should say.

These are not two versions of the same thing, and confusing them is the most common mistake US applicants make when comparing options.

Residence by investment, offered by Portugal, Greece and Malta, gives the right to live in that country and, in the European cases, to travel within the Schengen Area for up to 90 days in any 180-day period on the strength of the residence permit itself. It does not by itself change your citizenship, your passport, or your US tax position. Depending on the country, it can open a path toward permanent residence and eventually citizenship by naturalization, but that is a separate legal process with its own residence, language and civic requirements, assessed years later.

Citizenship by investment, offered by St Kitts and Nevis, St Lucia, Antigua and Barbuda, Dominica and Grenada, grants citizenship directly to an approved applicant after due diligence and a government decision, along with a certificate of naturalization. It does not require the applicant to live in the country, and it does not require giving up US citizenship. What it gives a US person who already holds a US passport is a second, unconditional legal identity and travel document independent of US policy, plus an optional foothold for future relocation. What it does not change is anything about US filing obligations, and it does not by itself create a right to live or work in Europe.

If your goal is a base to live in, with family healthcare, schooling and a long-term settlement path, start with the European residence routes. If your goal is a second citizenship as insurance, independent of relocation plans, Caribbean citizenship by investment is the more direct route and the European residence routes are the wrong tool.

Portugal's Golden Visa is formally the Residence Permit for Investment Activity (ARI), granted under Article 90-A of Law 23/2007 as amended by Law 56/2023. Direct real estate purchase was removed from the qualifying routes in October 2023, so the current qualifying options are a subscription to a CMVM-registered investment fund of at least €500,000, a capital transfer of at least €500,000 to scientific research activity at a Portuguese institution, a capital transfer of at least €500,000 to a Portuguese company that creates at least five permanent jobs, the creation of at least ten jobs with no minimum capital, or a donation of at least €250,000 to an approved arts or cultural-heritage project (reduced to €200,000 for GEPAC-approved projects in designated low-density territories).

ARI's main draw for a US applicant is the stay requirement: an average of seven days per year (14 days across each two-year renewal period), well short of the 183-day threshold that most countries use to trigger tax residence. That lets a family hold Portuguese residence without becoming a Portuguese tax resident purely by virtue of the permit, though tax residence depends on separate triggers (physical presence or a permanent home available in Portugal) and should be confirmed with a Portuguese tax adviser rather than assumed. ARI residence covers the investor, spouse, dependent children and dependent parents, and current AIMA processing realistically runs 18 to 36 months from application to a physical residence card, though residence rights begin on approval rather than on card issuance.

Citizenship by naturalization used to be available after five years of residence, but Lei Orgânica n.º 1/2026, in force since 19 May 2026, extended the general naturalization residence period to ten years (seven years for CPLP and EU nationals, a track US citizens do not qualify for). Applications for citizenship already filed with Portugal's registry office (IRN) on or before 18 May 2026 continue under the previous five-year regime; ARI holders who had not yet filed by that date are assessed under the new ten-year rule once they reach the eligibility window. A US applicant weighing Portugal today should plan around the ten-year timeline, not the five-year figure still common in older marketing material.

For US citizens who do not want to commit €500,000, Portugal also offers non-investment residence routes that are not Golden Visa products but matter for a lower budget. The D7 visa suits applicants with pension, rental or investment income set at the Portuguese minimum wage annually for the main applicant (€11,040 in 2026, plus roughly 50% for a spouse and 30% per dependent child), but it requires the standard 183-day physical presence to maintain residence, unlike ARI's seven-day rule. The D8 digital nomad visa suits remote employees or contractors earning at least four times the minimum wage (€3,680 per month in 2026) from a non-Portuguese employer. Clients on calls with My Golden Visa managers have specifically asked whether a US employer needs to be told about a D8-style move, since continuing US payroll from abroad raises separate US employment-tax and withholding questions for the applicant and, in some cases, the employer. That is another reason to loop in a cross-border tax adviser before filing.

Portugal previously offered NHR, a ten-year special tax regime; NHR has been replaced by IFICI, a narrower incentive regime available to eligible new tax residents. ARI does not automatically qualify a client for IFICI: eligibility is assessed separately once the applicant becomes tax resident, and it should not be assumed at the point of applying for the residence permit itself.

Learn more on the Portugal Golden Visa program page.

Greece's Golden Visa is a residence by investment permit issued under Law 5038/2023 as amended by Law 5100/2024. The real estate thresholds are geography-based: €800,000 for a single qualifying property in central Athens, Thessaloniki, Mykonos, Santorini and a handful of other high-demand areas; €400,000 for other developed areas, generally subject to a 120 sqm minimum floor area; and €250,000 for a listed or heritage building being restored, or for an industrial building being converted to residential use, both exempt from the size restriction. A non-real-estate route exists too: a Greek-domiciled investment fund or comparable financial instrument qualifies from €350,000, an option some US clients prefer specifically because it avoids the illiquidity and management overhead of holding Greek property, though a non-US fund still needs the same PFIC screening described above.

Unlike Portugal's ARI, the Greek Golden Visa carries no minimum physical presence requirement at all if the applicant is not pursuing citizenship: a five-year residence card, renewable indefinitely every five years, without a stay obligation to keep it valid. That changes only if the applicant later wants Greek citizenship: naturalization requires 183 days of physical residence per year for seven years, transition to EU long-term resident status around the five-year mark, and passing a Greek language and civic knowledge examination. Family inclusion covers spouse, children under 21 (with conditional inclusion for children 21–24), and parents or parents-in-law.

One structural point matters for anyone planning to sell: a Golden Visa holder cannot have a gap between owning a qualifying property and owning its replacement. Selling before a new qualifying purchase closes revokes the residence permit, which makes portfolio changes something to plan carefully rather than execute opportunistically.

Learn more on the Greece Golden Visa program page.

Malta offers two distinct routes for a US applicant, and conflating them is a compliance and a practical mistake.

The Malta Permanent Residence Programme (MPRP), governed by Subsidiary Legislation 217.26, grants permanent residence (not citizenship) to non-EU, non-EEA and non-Swiss applicants. Under the investment criteria in force since 22 July 2025, the main applicant pays a non-refundable government contribution of €37,000, administrative fees of €60,000 in total, a €2,000 charitable donation, and either purchases qualifying property from €375,000 or rents from €14,000 per year, alongside a demonstrated asset base of at least €500,000 (including €150,000 in liquid financial assets) or an alternative €650,000 portfolio (including €75,000 liquid). MPRP has no minimum stay requirement to maintain the permit, processing typically runs three to six months, and the application can include spouse, dependent children up to age 29, and parents or grandparents of either spouse. MPRP does not itself grant Maltese or EU citizenship, and it does not directly confer a special tax regime; those are separate matters requiring separate applications.

Malta citizenship is a different legal track entirely, available only by naturalization. Ordinary naturalization is possible after continuous Maltese residence, typically pursued after several years on MPRP status. Malta also operates a discretionary legislative framework for citizenship by naturalization for exceptional services, assessed individually by the competent Maltese authority on a case-by-case basis; this is not an investment program, it carries no fixed contribution amount or firm processing timeline that can responsibly be quoted here, and it is entirely separate from EU citizenship or EU rights framing. A US applicant interested in this route should treat every fixed number or promised timeline seen elsewhere as unverified until confirmed directly with Community Malta Agency or a Maltese lawyer.

Learn more on the Malta residence and citizenship options page.

St Kitts and Nevis, St Lucia, Antigua and Barbuda, Dominica and Grenada each run a citizenship by investment program under their own national law, typically offering a non-refundable government contribution option alongside a real estate option. St Kitts and Nevis, for example, currently sets its Sustainable Island State Contribution at US$250,000 for a single applicant or a family of up to four, or a real estate investment from US$325,000 in an approved development (with resale possible after a seven-year holding period). Dominica's Economic Diversification Fund contribution starts at US$200,000 for a single applicant, with a comparable real estate option. Exact thresholds, family surcharges and holding periods differ by island and change over time, so treat any specific figure as a starting point to verify against the current program rules for the jurisdiction you are considering, not a fixed price.

For a US citizen who already holds a globally accepted passport, Caribbean citizenship by investment is not primarily a travel-document upgrade. What it gives is an independent, unconditional second citizenship and its associated certificate of naturalization: a status that exists regardless of future US visa or travel policy, is available to future generations by descent, in some cases opens Commonwealth education and immigration pathways, and requires no minimum residence to obtain or keep. Processing for most of these programs runs around four months, sometimes faster under accelerated tracks.

What it does not change is anything about your obligations to the United States. A Caribbean citizenship does not create tax residence anywhere else on its own, does not exempt worldwide income from US tax, and does not remove FBAR or FATCA reporting duties. Applicants are also asked to disclose every citizenship they hold as part of due diligence; a second citizenship cannot be used to hide the US one, nor should it be positioned that way.

Learn more on the Caribbean citizenship by investment hub.

The table below maps the routes described above against the four factors that decide the outcome for a US citizen, built from the program detail set out above. Figures are approximate and subject to change; verify current thresholds before committing capital.

Investment figures above are approximate starting points for the main applicant only. They do not include government processing fees, due-diligence charges or family-member surcharges, which vary by programme and route. Confirm the full all-in cost for your family's situation with My Golden Visa before committing capital.

The pattern here matters: every route leaves US tax and reporting exposure exactly where it started. The only variable within your control is whether the qualifying investment itself creates additional PFIC complexity: a real estate purchase, a direct donation or a job-creation route generally does not, while a pooled non-US investment fund generally does.

Every one of these routes carries risk beyond the sticker price of the investment. Due diligence can delay or refuse an application if source-of-funds documentation is incomplete or inconsistent, and government authorities retain full discretion over the outcome; no provider can guarantee approval. Portugal's AIMA backlog means realistic processing is closer to 18–36 months than the 12 months sometimes quoted in marketing material. Fund-based investment routes carry market and liquidity risk on top of the PFIC tax treatment already discussed, and donation-based routes are irrevocable with no financial return by design. Selling a Greek qualifying property before completing a replacement purchase revokes the residence permit. Renewal and family-composition rules change as children age past dependant thresholds, so timing matters for families with teenagers or young adults. Rules themselves are not static: Portugal's naturalization timeline changed materially in 2026, and any of these countries can amend investment thresholds, due-diligence standards or family rules with limited notice.

None of these risks are unique to US applicants, but the tax and reporting layer above is, and it compounds every other risk: a delayed application, a fund substitution, or a change in family composition can each have separate US tax consequences that a general immigration adviser will not flag.

No. None of the routes described in this guide require a US citizen to renounce US citizenship, and US law does not require it either: the United States does not force a citizen to give up US nationality when they acquire a second residence or a second citizenship elsewhere. Expatriation is a separate, voluntary and irrevocable legal step some individuals choose for their own reasons, governed by its own US tax rules (including a potential exit tax under the covered-expatriate regime) that are entirely independent of any residence or citizenship by investment program. If expatriation is something you are considering, that decision needs its own conversation with a US tax attorney. It is not a byproduct of any Golden Visa or citizenship by investment application, and nothing in this guide should be read as advice toward or against it.

Start from the goal, not the country list. If the priority is a European base the family will live in, with a real long-term settlement plan, Portugal's ARI or Greece's residence route are the candidates, and the choice between them usually comes down to whether a near-zero stay requirement (Portugal) or no stay requirement at all until citizenship is pursued (Greece) matters more, plus whether the household prefers a fund/donation structure or a property purchase. If the priority is Malta specifically, for its English-language environment, healthcare or Mediterranean base, MPRP is the route, with Maltese citizenship treated as a separate, much longer-horizon question that should not be assumed at the outset. If the priority is a second citizenship as standalone insurance, independent of ever relocating, Caribbean citizenship by investment is the direct route, and comparing the European residence programs against it is comparing two different products. Whichever direction fits, screen every qualifying investment for PFIC exposure and loop in a US cross-border tax adviser before funds move, not after.

My Golden Visa's advisers work through this fit assessment with US clients directly, cross-checking current program thresholds, family eligibility and processing timelines against your specific goal before you commit capital. Contact My Golden Visa to talk through which route matches your situation, or explore the full range of options in the Golden Visa guides.