International Private Wealth

International Private Wealth Management

International private wealth management is a crucial component of financial planning for individuals and families leading an international lifestyle. This lifestyle could be due to various factors such as personal, health, political, or professional reasons. For instance, it could involve working in a multinational corporation, emigrating for better opportunities, studying in a foreign university, or owning properties or businesses in different countries.

Complexities in Wealth Management

The international lifestyle, while offering many advantages, also complicates wealth management. This is particularly true in the area of tax planning. For example, wealth managers and financial experts help their clients navigate complex income, asset, wealth, and transfer considerations in different tax jurisdictions.

Intersection of Citizenship, Residency, and Taxation

The intersection between citizenship, residency, and individual tax situations is critical in international private wealth management. For instance, while taxation and citizenship often align, there are cases where they operate independently. Tools such as tax treaties and double taxation agreements allow individuals to change their residency for tax purposes.

Value of Citizenship

Citizenship is valuable, especially in countries with political, economic, and social stability. Some countries like Monaco offer unique tax benefits, such as low taxation on certain types of income. For instance, some countries tax only their residents, regardless of citizenship, while others like the United States tax their citizens no matter where they reside.

Attracting Financial Capital

Certain countries like Ireland actively attract financial capital by offering favorable residency and tax conditions. These include clear double taxation rules and even the option of acquiring citizenship for those with substantial financial resources. External factors dynamically influence these scenarios, with countries and states competing to attract desirable taxpayers through varied tax incentives.

Systems of Citizenship

Citizenship is a legal bond between an individual and a state, conferring various rights, duties, and responsibilities. The rules of citizenship differ from country to country, impacting aspects such as tax, asset protection, and inheritance laws. Understanding the complex criteria for acquiring citizenship in each country is crucial.

• Citizenship by Birth: The most common way of acquiring citizenship is by birth. For example, in the United States, a child born to American parents, regardless of where the birth takes place, is granted citizenship. This is known as jus sanguinis or “right of blood” or citizenship by descent. Some countries, like the United States, also grant citizenship to those born within their borders, a system based on jus soli, or “right of soil,” or birthright citizenship.
• Citizenship by Extended Descent: Some countries, such as Italy, grant citizenship based on the heritage of grandparents or, in some rare cases, even great grandparents who resided in formerly controlled territories. This emphasizes the complexity of historical and familial ties in citizenship laws.
• Citizenship through Naturalization: Naturalization is another route to citizenship, typically for those who have legally entered a country, including political asylum, and have lawfully lived there for a mandated period. For instance, in Canada, naturalized citizenship candidates are required to take a test demonstrating an understanding of the country’s laws, culture, history, traditions, and language. Some countries mandate renouncing prior citizenships before granting naturalization, while others legally permit dual or multiple citizenship.
• Citizenship by Marriage: In the aftermath of World War II, the concept of acquiring citizenship through marriage, also known as “right of matrimony” or jus matrimonii, has gained traction. This form of naturalization allows a non-citizen spouse to obtain citizenship after a certain period of marriage or residency in the country. For instance, in the United States, a foreign spouse can apply for citizenship after three years of marriage to a U.S citizen. Some nations extend this right to civil partnerships, although this is not universally accepted.
• Citizenship by Investment: Another pathway to citizenship is through significant financial contributions or investments in a country’s economy, a process known as “economic citizenship” or Citizenship by Investment (CBI). For example, Malta offers citizenship to individuals who invest a minimum of €650,000 in the national development fund. The forms of investment can range from real estate purchases, business investments, acquisition of government debt, or deposits in specific financial institutions. Applicants for CBI must generally meet certain age, criminal record, and income eligibility requirements.

While CBI is not universally offered, many Caribbean countries, such as St. Lucia, Grenada, and St. Kitts and Nevis, provide this option. There are also intermediate options like golden visa or residency by investment programs, which provide pathways to eventual citizenship. Many of these programs do not impose residency requirements, allowing wealthy individuals to obtain a residence permit in exchange for a significant investment, and then offer various alternatives to gain citizenship.

Dual Citizenship

Dual citizenship is a status that allows an individual to be a citizen of two or more countries simultaneously. This is recognized by many countries including the United States, United Kingdom, South Africa, Australia, and Hong Kong (SAR). However, some countries like Argentina only permit dual citizenship with specific countries such as Italy and Spain, often based on economic relationships.

Benefits of Dual Citizenship

• Asset Diversification: Dual citizenship allows high-net-worth families to diversify their investments across countries. For example, a US citizen with dual citizenship in Australia can invest in both US and Australian real estate markets.
• Global Mobility: Multiple passports simplify international travel and business expansion. For instance, post-Brexit, UK citizens with dual citizenship in an EU country found it easier to travel within Europe.
• Tax Optimization: Dual citizenship provides opportunities for tax optimization. For example, a citizen of the US and the Bahamas can take advantage of the Bahamas’ more favorable tax laws.
• Access to Global Facilities: Dual citizenship provides greater access to top educational and medical facilities worldwide.
• Political Safety Net: In case of political instability in one country, dual citizenship provides alternative options for relocation. For example, a citizen of Hong Kong and Australia can relocate to Australia during times of political unrest in Hong Kong.

Challenges and complexities

While dual citizenship can offer a range of benefits, it also presents a unique set of challenges and complexities. These include legal and administrative burdens, potential double taxation, cultural challenges, and political and economic risks.

• Legal and Administrative Burden: Managing dual citizenships involves navigating through diverse regulations and paperwork, akin to a US citizen living in Germany having to comply with both US and German laws. Incorrect tax filings or residency documentation can lead to potential financial penalties, much like penalties imposed by the IRS for incorrect tax filings.
• Double Taxation: While dual citizenship can be tax efficient, it also carries the risk of dual taxation. For example, a Canadian citizen living in the US might be taxed in both countries. Understanding tax treaties and filing requirements for each country is crucial to avoid being taxed multiple times on the same income or assets.
• Cultural Challenges: Having identities in different countries can erode one’s sense of belonging and pose social difficulties. This is especially true for children who frequently relocate, as they may face difficulties in forming stable friendships and struggle in developing a consistent sense of home and cultural identity.
• Political and Economic Risks: Having citizenship in politically or economically unstable countries exposes families to potential losses due to nationalization or illegal expropriation of assets. For example, a Venezuelan citizen might face economic instability due to the country’s current political climate.

Legal Residence and Tax Domicile

Legal residence is the country where an individual is deemed a resident for tax purposes. This can be intricate due to varying definitions of residency across countries. For instance, a family might be classified as residents in both the United States and Canada, leading to complex taxation considerations.

Tax domicile

Tax domicile is the country where an individual is considered a tax resident. Factors such as the type of residency, duration of stay, economic ties, and family or social connections to a country play a role in establishing tax domicile. For example, a businessman who spends most of his time in Germany but has strong economic ties to France might face complexities in determining his tax domicile.

It is essential for every individual to have a designated principal tax residence to avoid ambiguity in taxation. This is typically the country where the individual resides most frequently or has significant connections. For instance, a person might qualify as a tax resident in both the UK and Australia, leading to potential tax liabilities in both jurisdictions.

Effective wealth management for multijurisdictional families necessitates strategic planning to minimize tax liabilities. Income generated by assets located outside an investor’s home country may be taxed in both the country where the income originates and the country where the wealth owner resides. For example, a property owned in Italy by a US resident might be subject to taxation in both countries.

Taxable Claims and Jurisdiction

Jurisdiction refers to the authority a country has to tax income or assets. A country that taxes income generated within its borders is said to have source jurisdiction, also known as a territorial tax system. However, the interaction of different country tax systems can lead to tax conflicts, where two countries claim taxing authority over the same income or assets. These conflicts can relate to any taxable event such as income, capital gains, gifts, or inheritance.

Exploring Types of Tax Conflicts

• Residence–Residence Conflict: This conflict arises when an individual is considered a tax resident in two different countries. For instance, a person living in Canada but working in the United States may face this conflict. Both countries may assert the right to tax the individual’s non-source income, leading to potential double taxation.
• Source–Source Conflict: This conflict can occur when an individual owns a business physically located in one country, but the business operations are managed from another country. For example, a company headquartered in Germany but operating in France could face this conflict. Both countries claim that the business income should be taxed in their jurisdiction, leading to complex tax obligations.
• Residence–Source Conflict: This conflict occurs when taxation obligations are global. It is one of the most common and challenging types of tax conflict. For example, a US citizen who owns real estate in Singapore. The United States considers the individual a tax resident and claims the right to tax their worldwide income. Singapore also wants to tax the rental income from the property because it falls under its source jurisdiction. The individual thus faces the difficulty of potentially being double taxed unless they can find relief through mechanisms like foreign tax credits or Double Taxation Treaties (DTTs).

Mitigating Double Taxation

The primary jurisdiction over tax income within a country’s borders is generally considered to be the source country. However, conflicts can arise between the residence and source countries, leading to potential double taxation. To mitigate this, the residence country can provide relief through three methods: the credit method, the exemption method, and the deduction method.

• The Credit Method: The credit method is a common approach used to avoid double taxation. It allows taxpayers to offset their domestic tax liability with the taxes already paid in a foreign country. For instance, if a US-based company operates in Germany and pays taxes there, it can offset these taxes against its US tax liability. However, the credit claimed cannot exceed the amount owed under the home country tax jurisdiction. The formula for this method is:

$$\text{Tax rate via credit method} = \max(\text{Domestic tax rate}, \text{Foreign tax rate})$$

• The Exemption Method:The exemption method is another approach where the home country relinquishes its taxation rights on foreign-source income. This means that the taxpayer only owes taxes to the foreign country where the income originates. For example, if a Singaporean company operates in Thailand, it only pays taxes in Thailand. The formula for this method is:

$$\text{Tax rate via exemption method} = \text{Foreign tax rate}$$

• The Deduction Method:The deduction method reduces the taxable income by the amount of qualifying taxes already paid to a foreign government. This method does not eliminate double taxation but reduces the overall tax liability. For instance, if a UK-based company operates in France, it can deduct the taxes paid in France from its taxable income in the UK. The formula for this method is:

$$ \begin{align*} \text{Tax rate via deduction method} & = \text{Domestic tax rate} + \text{Foreign tax rate} \\ & – (\text{Domestic tax rate} \times \text{Foreign tax rate}) \end{align*} $$

Foreign Tax Credit Provisions

The foreign tax credit provisions are a crucial part of the domestic tax codes in various countries, designed to prevent double taxation for residents with income or assets abroad. These provisions can apply to different tax categories, including income, gift, or estate tax.

The mechanism of these provisions is based on the primary taxing rights of the source country. For instance, consider a scenario where a domestic tax rate is 50% and a foreign tax rate is 40%. The total tax liability would be 70%, with the foreign country collecting 40% and the home country collecting the remaining 30%. This demonstrates how the home country concedes a part of its tax claim.

Foreign Tax Credit Provisions

Different countries have unique foreign tax credit provisions. For instance, the United States provides foreign tax credit relief for income and estate taxes but not for gift taxes. In contrast, France offers relief for gift and estate taxes but excludes income taxes. Spain, however, provides comprehensive relief covering income, gift, and estate taxes.

It’s crucial to note that a foreign tax credit provision doesn’t dictate the specific method a country uses to mitigate double taxation. Countries may use the credit, exemption, or deduction method, or even a unique approach. For example, the United States offers the Foreign Earned Income Exclusion (FEIE) to its citizens and residents with a tax home in a foreign country, allowing for the exclusion of up to USD120,000 of income annually from taxation.

Double Taxation Treaties (DTTs)

DTTs are international agreements designed to prevent the same income from being taxed twice, thereby promoting global trade and investment. For instance, a company like Apple, which operates in multiple countries, would not be taxed twice on the same income due to these treaties. There are over 2,000 active DTTs that resolve conflicts between residence and source countries.

The The Organisation for Economic Co-operation and Development (OECD) Model Tax Convention

OECD Model Tax Convention on Income and on Capital, also known as the OECD Model Treaty, serves as a guideline for DTTs. It aims to standardize international taxation rules and eliminate double taxation. For example, if a UK-based company has a branch in France, the treaty outlines how taxes should be levied on the income generated in France, eliminating double taxation. The treaty is widely used by both OECD member and non-member countries.

International Trade, Investment, and Capital Flows

With the rise of global trade and investment, countries sought to retain tax revenues from assets and revenue generated in other jurisdictions. For instance, if a US-based company has a subsidiary in India, the US would want to tax the income generated in India. This issue is addressed through either domestic legislation or bilateral tax treaties.

Exemption or Credit Method

The Model Treaty advocates for using either the exemption or credit method to settle double taxation conflicts. It predominantly covers direct taxes, such as income and capital taxes on business profits, dividends, interest, and royalties, as well as capital gains from the disposition of property. It does not typically address indirect value-added or sales tax.

Prevention of Tax Evasion and Avoidance

The treaty includes mechanisms to prevent tax evasion and avoidance, such as sharing taxpayer information between countries. It includes specific anti-abuse provisions to counter tax evasion tactics, like treaty shopping, where an individual or entity attempts to leverage treaty tax advantages without genuine economic activities in either country.

Residency and Source State in Taxation

The term ‘resident’ in the Model Treaty refers to an individual or entity that is liable to pay tax in a particular country based on factors such as domicile or physical presence. For instance, a US citizen living and working in the UK would be considered a resident of the UK for tax purposes. The ‘source state’ is the jurisdiction where the income originates, usually where the related economic activity occurs. For example, if a company based in Germany generates income from its operations in France, France would be the source state.

Double Taxation Relief

Double taxation relief is a crucial aspect of international taxation. The Model Treaty supports the use of credit and exemption methods for this purpose, aligning with unilateral domestic provisions. For instance, if a Canadian company earns income in the US, it may be taxed in both countries. However, the company can claim a foreign tax credit in Canada for the taxes paid in the US, thereby avoiding double taxation.

Investment Income and Capital Gains Taxation

Investment income, such as dividends and interest, is taxed by the source state. The Model Treaty caps the withholding tax rates at 15% for dividends and 10% for interest. For example, if a UK resident earns dividend income from a US company, the US (source state) can withhold tax at a maximum rate of 15%. On the other hand, capital gains are taxed in the seller’s residence country.

Tax Liability in Real Estate Sales and Dual-Residency

The taxation of real estate sales is unique in that the tax liability is typically determined by the physical location of the property. For instance, if a US resident sells a property located in Canada, the Canadian government has the right to tax the capital gains from the sale. This is a departure from the usual practice where the resident’s country has the primary right to tax global income.

Dual-Residency Taxation

In situations where an individual qualifies as a dual-resident taxpayer due to factors such as domicile or place of management, tax treaties provide tie-breakers. These are based on the location of the individual’s permanent home, center of vital business interest, habitual dwelling, and citizenship. However, these treaties typically do not resolve conflicts involving only source countries.

Double Taxation Treaties (DTTs)

Countries like Switzerland generally use the exemption method in their DTTs. However, for countries without a DTT, Switzerland employs the credit method for foreign-source taxes. France has a DTT with Sweden that covers income, gift, and estate taxes, while its treaty with Spain only covers income taxes.

Double taxation on gift and estate taxes can often be mitigated through domestic foreign tax credit provisions in both countries. Most DTTs focus on income taxes, as many jurisdictions lack estate taxes, making an estate-specific DTT unnecessary. To avail themselves of any treaty benefits, taxpayers must meet the residency criteria specified in the treaty.

Ending Tax Residency

Tax residency is a crucial concept in the field of personal finance and taxation. It determines an individual’s tax obligations within a specific country, not only based on citizenship but also on factors such as length of stay, family ties, property ownership, and income sources. Changing tax residency involves more than just relocation; it requires establishing a new permanent address and, if necessary, obtaining immigration documentation.

Establishing and Terminating Tax Residency

Each country has unique rules and procedures for establishing or terminating tax residency. Short-term stays, such as vacations or temporary work assignments, are often insufficient. Establishing permanent residency and shifting daily activities to another country are critical steps for terminating tax obligations in the original jurisdiction.

Complexities in Terminating Tax Residency

The residency status of immediate family members can complicate the process of terminating tax residency. For instance, maintaining a residence for immediate family members in the original jurisdiction can extend tax obligations and limit the ability to terminate tax residency.

State Residency vs National Residency

Changing state residency for tax purposes is often simpler than changing national residency. For example, in the United States, high-income individuals often move their residency to Florida, a state with no state income taxes or estate taxes, making it attractive for retirees and those with high accumulated wealth.

Consequences of Non-Adherence

Non-adherence to jurisdictional tax laws can lead to significant repercussions, potentially affecting future tax obligations, including the increased risk of double taxation. It may also jeopardize long-term financial health and legal residency, including protection of assets in both jurisdictions.

Renouncing Citizenship

Renouncing citizenship is a complex process that involves legal, bureaucratic, and tax obligations. It is often considered by multijurisdictional families with multiple citizenships to simplify their responsibilities across different jurisdictions. The decision to renounce citizenship is serious and often emotional, involving intricate legalities and potential tax repercussions.

Reasons for Renouncing Citizenship

• Financial Relief: For example, a US citizen living and working in Singapore, who is subject to worldwide taxation, may find financial relief in renouncing US citizenship. However, this only becomes effective after all due taxes have been paid, including possible exit tax obligations.
• Avoiding Military Conscription: For instance, a young man from South Korea, where military service is mandatory, may renounce his citizenship to avoid conscription, especially if he has dual citizenship in a country without such obligations.

Exit Tax

Another factor influencing the decision to renounce citizenship can be an exit tax. This is a tax levied by the country whose citizenship is being renounced to compensate for lost tax revenue. For instance, a French citizen moving to the United States might be subject to this tax. Exit taxation is generally not applicable for capital moving between EU countries but could apply to capital moving outside the EU. These regulations often change, adding another layer of complexity to the decision-making process.

Exit tax is a form of taxation imposed on unrealized gains accrued on assets when they are transferred out of a taxing jurisdiction. This tax is triggered by a deemed disposition, which results in the taxation of any previously unrecognized capital gains. The tax is not levied on the principal value of the transfer, but only on the value of unrecognized gains, if any.

Shadow Period

The exit tax may also include an income tax on income earned over a fixed period after expatriation, known as a “shadow period”. For instance, if a US citizen moves to Canada and earns income in the first year after moving, this income may be subject to the US exit tax.

United States Exit Tax

The United States is one of the few countries that tax its citizens on worldwide income. This has led some individuals who permanently reside abroad to renounce their US citizenship for tax reasons. These individuals are subject to an exit tax, which is aimed at preemptively capturing taxes on future liabilities such as unfiled returns or deferred capital gains. This tax assumes a deemed sale of all global assets at their fair market value one day before expatriation. The scope of this tax includes a wide variety of property, from financial instruments to personal items like cars and jewelry.

The exit tax is levied on those with a net worth over USD2 million. It also applies to long-term non-citizen residents, defined as those who have been lawful permanent residents for at least eight of the last fifteen years who terminate their US residency and move elsewhere.

Residency Through Investment Visas

Investment visas serve as a strategic tool for individuals seeking to reap legal, tax, and economic benefits in a country with less regulatory, tax, and administrative burdens. They are part of a broader spectrum of visa options, including work visas, student visas, and golden visas.

Types of Visas

• Work Visas: For example, an H-1B visa in the United States allows foreign professionals to work temporarily in the country.
• Student Visas: An example is the F1 visa in the United States, which allows foreign students to study at U.S. universities.
• Investor Visas: The EB-5 visa in the United States grants temporary residency in exchange for investments in local businesses or industries.
• Golden Visas: Portugal’s Golden Visa program offers residency, work rights, and a path to citizenship through significant investments in real estate or business ventures.

Benefits of Investment Visas

Investment visas are attractive to affluent families for visa-free travel and financial benefits. They also provide a legal avenue to relocate assets to a country with potentially favorable tax treatment and legal asset protection. However, it’s crucial to remember that tax laws, residency, and nationality laws are subject to frequent changes, requiring ongoing adjustments in financial strategies.

Awareness of External Factors

Effective tax planning and decision-making necessitate an understanding of dynamic external factors. For example, in countries like the United States and Switzerland, state or local regulations can lead to significant variations in tax regimes.

Practice Questions

Question 1: A high net worth individual is considering relocating due to professional reasons and is seeking advice on international private wealth management. They are particularly interested in understanding the complexities involved in managing wealth internationally, the intersection of citizenship, residency, and taxation, and the potential benefits of citizenship in different countries. As a financial expert, explain the importance of understanding the intersection between citizenship, residency, and individual tax situations in international private wealth management?

1. It is important because taxation and citizenship often align, and there are tools available that allow individuals to change their residency.
2. It is not important because most countries tax only their residents, regardless of citizenship.
3. It is important because some countries offer unique tax benefits, such as low taxation on certain types of income.

Answer: Choice A is correct.

Understanding the intersection between citizenship, residency, and individual tax situations is crucial in international private wealth management. This is because taxation and citizenship often align, and there are tools available that allow individuals to change their residency. The tax implications of citizenship and residency can significantly impact an individual’s net wealth. Different countries have different tax laws and rates, and these can vary depending on whether an individual is a citizen, a resident, or both. For example, some countries tax their citizens on their worldwide income, regardless of where they live. Others only tax residents on their worldwide income, while non-residents are only taxed on income earned within the country. Furthermore, some countries have tax treaties with other countries to avoid double taxation. Therefore, understanding these complexities can help individuals make informed decisions about where to live and how to manage their wealth. Additionally, there are tools and strategies, such as tax planning and offshore banking, that can help individuals optimize their tax situation and protect their wealth.

Choice B is incorrect. While it is true that most countries tax only their residents, there are exceptions. For example, the United States taxes its citizens on their worldwide income, regardless of where they live. Therefore, understanding the intersection between citizenship, residency, and taxation is important in international private wealth management.

Choice C is incorrect. While it is true that some countries offer unique tax benefits, such as low taxation on certain types of income, this is only one aspect of the intersection between citizenship, residency, and taxation. Understanding this intersection involves much more than just knowing about tax benefits in different countries. It also involves understanding the tax implications of citizenship and residency, as well as the tools and strategies available to manage wealth internationally.

Question 2: An individual is considering changing their residency due to personal reasons and is seeking advice on international private wealth management. They are particularly interested in understanding the value of citizenship in different countries. As a financial expert, explain the value of citizenship, especially in countries with political, economic, and social stability?

1. Citizenship is valuable because some countries tax only their residents, regardless of citizenship.
2. Citizenship is not valuable because most countries tax their citizens no matter where they reside.
3. Citizenship is valuable because some countries offer unique tax benefits, such as low taxation on certain types of income.

Answer: Choice C is correct.

Citizenship is valuable because some countries offer unique tax benefits, such as low taxation on certain types of income. The value of citizenship, especially in countries with political, economic, and social stability, can be significant. These countries often have well-established tax systems that offer various benefits to their citizens. For instance, some countries may have lower tax rates on certain types of income, such as capital gains, dividends, or interest. Others may offer tax credits or deductions for certain expenses or investments. Additionally, countries with political, economic, and social stability often provide a safe and secure environment for individuals and their assets. They may have strong legal systems that protect property rights and enforce contracts, as well as stable political systems that reduce the risk of sudden policy changes. Furthermore, these countries may offer social benefits such as access to quality healthcare and education, which can further enhance the value of citizenship. Therefore, when considering changing residency for personal reasons, it is important to understand the tax and other benefits that citizenship in different countries can offer.

Choice A is incorrect. While it is true that some countries tax only their residents, regardless of citizenship, this does not fully capture the value of citizenship. Citizenship can offer a range of benefits beyond tax considerations, including legal rights, social benefits, and access to certain opportunities and services.

Choice B is incorrect. While it is true that most countries tax their citizens no matter where they reside, this does not mean that citizenship is not valuable. As mentioned above, citizenship can offer a range of benefits beyond tax considerations. Moreover, the tax implications of citizenship can vary widely from one country to another, and some countries do offer unique tax benefits to their citizens.

Glossary

• International Private Wealth Management: A component of financial planning for individuals and families leading an international lifestyle.
• Tax Liability: The total amount of tax that an individual, company, or organization owes to the government.
• Taxable Income: The amount of income that is subject to tax.
• Jus Sanguinis: The right of blood, a principle of nationality law by which citizenship is determined by having one or both parents who are citizens of the state.
• Jus Soli: The right of soil, a principle of nationality law by which citizenship is determined by place of birth.
• Jus Matrimonii: The right of acquiring citizenship through marriage.
• Citizenship by Investment (CBI): A process where individuals can gain citizenship by making significant financial contributions or investments in a country’s economy.
• Dual Citizenship: The status of an individual who is a legal citizen of two countries.
• Double Taxation: The levying of tax by two or more jurisdictions on the same declared income or assets.
• Double Taxation Treaties (DTTs): Agreements between two or more countries to prevent double taxation.

Private Wealth Pathway Volume 2: Learning Module 6: Advising the Wealthy; LOS 6(a): Discuss and recommend appropriate citizenship, nationality, and legal residency approaches for private clients.