Moving from the US to Hong Kong
Hong Kong's territorial system and two-tier standard-rate cap can be attractive locally. They do not, however, switch off US citizenship-based taxation, so the real question is which income Hong Kong taxes and which income the US still taxes.
Hong Kong solves the local rate question
Hong Kong's salaries tax is the lower of its progressive scale and a standard-rate cap: 15% on the first HKD 5,000,000 and 16% above.
Foreign-source income is generally not taxed, and Hong Kong has no capital gains tax, dividend tax, wealth tax or estate duty. That is a meaningful local distinction for an internationally invested family.
The IRS still sees the worldwide picture
A US citizen or green-card holder remains taxable by the US on worldwide income. US long-term gains are 0/15/20% plus 3.8% NIIT, while a renunciation by a covered expatriate can trigger IRC §877A.
The structure therefore has to separate local source analysis, foreign-tax credits and ownership. Hong Kong's exemption is not a personal US exemption.
Immigration is a separate decision
The Capital Investment Entrant Scheme requires HKD 30M total: HKD 27M in permissible assets, with residential property capped at HKD 10M, plus HKD 3M into the CIES portfolio. From 1 March 2026, qualifying family-office holding-company structures can be used with HKD 240M or more of AUM.
Before you move
- Do not use the 17% progressive top rate as the expected HNW ceiling; the two-tier standard-rate cap changes the result.
- Hong Kong's territorial treatment does not remove US reporting and tax on worldwide income.
- A day-count threshold was not verified for Hong Kong; ordinary-residence concepts need local advice.
Continue your research
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Tax rates are only the first screen. Residency, ownership, treaty position and succession can change the outcome.
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