This article examines developments ranging from President Trump's new "gold card" to attract HNW immigrants across to reports that HNW Americans are considering heading overseas.

The following article is from David Lesperance, of Lesperance Associates. He is an expert on taxation and citizenship. Based in Canada, Lesperance is knowledgable on citizenship/residency-by investment programs, and other issues facing affluent and high net worth individuals seeking to improve their lives and reduce the impact of heavy taxes. (He has written about such matters before in Family Wealth Report.)

Given present circumstances, this article is highly relevant. The US is reportedly seeking to entice HNW individuals with a “golden card” system; on the other hand, alarm at the Trump administration’s policies in some quarters is, so it is said, encouraging HNW Americans to think about leaving the country. In the UK, similarly, there are fears that the Labour government’s enthusiasm for hitting wealthy individuals with tax hikes will produce an exodus. Advisors to such persons have rarely been busier.

This article will, we hope, shed light on the situation and encourage debate. Guest articles are designed to start and continue conversations: if you have comments, criticisms and suggestions, please join in and get in touch with us at tom.burroughes@wealthbriefing.com and amanda.cheesley@clearviewpublishing.com.

Over a decade ago I co-authored a book with London School of Economics professor Ian Angell called The Flight of the Golden Geese: How the 1 per cent Matter to the 99%. In that book we examined the reality that in any country with a progressive tax system, whether deemed fair or unfair, a tiny number of taxpayers account for an extraordinary percentage of annual personal tax revenues. In the US, this coterie of taxpayers accounts for just over 40 per cent of the annual personal tax collected.

Once one also includes other economic benefits of the Golden Geese such as capital investment, consumer spending, employment, entrepreneurship and other tax contributions such as sales, property and other taxes, one recognizes that an essential element of a successful economy is to cultivate, retain and attract these individuals.

Is the Trump Card going to attract new Golden Geese to the US?
In a recent interview with Axis, Commerce Secretary Howard Lutnick made the latest of many claims about the â€śTrump Card,” which is the current US administration’s proposed vehicle for attracting foreign Golden Geese to America’s shores. Secretary Lutnick’s claims in that interview included: â€śEveryone who is not an American and who has the fiscal capacity will want the Trump Card” and “If 200,000 people pay that’s a trillion dollars…that pays for everything.” 

The real-world questions are “What are the target markets for the Trump Card?” And “Is the Trump Card a viable proposition to those target markets?” As an advisor for over 35 years to HNW international families, I can confirm that there are four possible target markets for the Trump Card. Let's look at it from their perspective.

Target Market 1: Wealthy businesspeople who want access to the US
This group can already get long-term access to the US through non-immigrant visas such as L-1, E1/E2, O-1 etc. If they either spend less than the time allotted under the Substantial Presence Test or have either a Closer Connection or Treaty Election to overcome the SPT, they will not become US taxpayers subject to US global taxation.

The major promoted feature of the "Trump Card" is that the holders will only be subject to US territorial taxation. To actually make this happen would require a change to the definition of being a US person for tax purposes in the Internal Revenue Code. There would need to be a new category that outlines how Gold Card holders' tax obligations are different from the worldwide tax obligations of citizens, Green Card holders and those who trigger the Substantial Presence Test. 

Not only is it impossible to make such a significant legislative change by Executive Order, it is almost guaranteed that there will never be enough votes in both houses to overcome the filibuster to make such a change. If it was included in a budget reconciliation bill it would only be effective for a maximum 10-year period as a result of the Byrd Rule. Notably, the necessary proposed changes are not even included in the House passed version of the One Big Beautiful Bill Act that is being discussed in the US Senate.

Without this benefit, the Trump Card has no advantage to justify a price tag that is 6.2 times more expensive than an EB5...for those who are willing to expose their global wealth to US taxation.

Secretary Lutnick has previously stated that there are 37 million people in the world who could afford this. He even claimed that 1,000 Trump Cards had already been sold. This is even though not only does the Trump Card still not exist in law, at the time of that statement there wasn't even a website where one could register interest. Furthermore, one does not spend their entire fortune on a donation to the US government for the honor of being a US taxpayer. So in reality, it is generally acknowledged that people would only spend 1/6th of their wealth (i.e. more than $30 million net worth). According to Wealth X, there are only 395,070 such individuals in the world with 225,000 of them already American taxpayers. That leaves a possible total market of 170,000 individuals...not 37 million or even 200,000. 

Target Market 2: Those who want to lobby President Trump
This target market of foreigners will do something that directly benefits Trump such as buying the Trump Coin rather than throw away $5 million for the right to be taxed globally for the rest of their lives (and estate after their passing).

Target Market 3: Employers who want to hire "the top graduate from Wharton or MIT"
Such employees can be hired in several cheaper and faster ways including:

1) H1B visa then employer sponsored Green Card in a few years;
 
2) Funding E2 visa which would consult to employer and then employer sponsor Green Card in a few years; or
 
3) Get the employee a Canadian work permit then permanent residence in their Canadian subsidiary. Immediately get B1/B2 visa to visit for regular headquarter meetings. After a year they could then apply for L-1 visa. After Canadian citizenship is granted (a three-year naturalization period), bring them in without limit on a TN visa. The employee could also get an employer sponsored Green Card.

In conclusion, the second and third target markets will find better, cheaper ways of reaching their goals. For the first target market let's assume that the Trump Card replaces the current EB5 Visa and does not have the territorial tax feature. Currently the EB5 visa has a price point of $800,000. In 2024 (a record year) a total of 12,055 were sold. With the price point jumping 6.2 times AND the cost moving from an investment to a donation, it is reasonable to expect this number to drop significantly if the EB5 visa was replaced by the Trump Card. In short, the Golden Geese are not going to being lured to the US by the Trump Card…should it ever even become a reality.

Is the US losing Golden Geese?
Along with helping international families, over those 35 years of practice I have also been assisting Americans with integrated international tax and immigration strategies. This has included hundreds of Americans who have renounced their US citizenship for tax purposes. While the number of wealthy Americans continues to increase, in the last decade this group has been overshadowed by those who seek a second residence and/or citizenship as fire insurance against the political wildfire which has engulfed the US. 

In fact ever since the 2024 US election, and especially since the inauguration and flood of executive orders, I have seen a dramatic uptick in the number of wealthy American families who have retained me to secure fire insurance as part of a fire escape plan to either live abroad or actually expatriate. 

The reasons vary and it is often a combination of the following:

-- Fear of retribution as they were high profile democratic supporters and/or critics of Donald Trump such as Timothy Snyder and his wife;

-- Defunding of research and attacks on elite universities;

-- Concerns about mass shootings, rising prejudice based on religion, race, or sexual orientation;

-- Concerns about a rise in political polarisation spurring increasing political violence;

-- Concerns that "Liberation Day" will cause dramatic increases in inflation, devaluation of the US dollar, jitters on US bond and stock markets resulting in unemployment significantly increasing. In turn these job losses will result in dramatically increased economic chaos which further fuels political violence. It only took four days after "Liberation Day" before I got my first inquiry from an UHNW American entrepreneur to "get me out of this political and financial dumpster fire."

As a result of one or many of these factors many American Golden Geese are either eying the exits or actually going through them. The loss of intellectual capital is astounding and will be difficult to reverse in the future. In summary, the loss of American Golden Geese is significantly greater than those who would ever be attracted to the US.

What is the future impact of the net loss of Golden Geese to the US?
When considering annual tax revenue, it is worth noting that the net loss of even a tiny number of Golden Geese from the US has a huge asymmetric impact on annual tax revenues. This is a result of not only the hyper-dependency on Golden Geese for over a 40 per cent of the annual personal tax revenue. It is also a function of the fact that since the US does not have a Value Added Tax and has low corporate tax collections, there is an unusually high over dependence on personal tax collections to fund the US budget. Aside from a few “true believers” in the White House, no serious economists believe that the loss of personal tax revenue can be replaced by tariff revenues.

The predictable future is that the current and future US administrations will see a long-term significant decrease in tax collections. Combined with increased interest payments on the ever-expanding US debt eating up more and more of the annual US budget, one does not need to be Nostradamus to predict a rocky future for the US left behind by departing Golden Geese.