Three routes make most American shortlists. The right one depends on how much of your life is actually moving.
The American families who contact us rarely want to leave the United States. They want a second door: a European residence permit held alongside a life that carries on in Denver or Boston, with the option of spending more time abroad as the children grow and careers change. That instinct has become far more common. Portugal’s immigration agency recorded 20,959 US citizens registered as residents in 2024, up from 14,126 the year before (AIMA).
Three routes make most American shortlists: Portugal’s Golden Visa, Portugal’s D7 and Italy’s Investor Visa. This guide compares them on the points that genuinely separate them, and on the US tax questions that apply to all three. For the wider picture of why so many Americans are looking abroad, our piece on why Americans are leaving the US sets it out.
| The choice usually comes down to one honest answer: how much of your family’s life is actually moving to Europe? |
How the Golden Visa works for Americans
US citizens qualify on exactly the same terms as any other non-EU national. The investment is a €500,000 subscription to a fund regulated by the CMVM, Portugal’s securities regulator; our guide to CMVM regulated funds explains that oversight. The presence requirement is an average of seven days a year. And since 19 May 2026, holders become eligible to apply for citizenship after ten years of legal residence, counted from the first residence permit. The shorter seven year track applies only to EU and CPLP nationals, so Americans are on the ten year count, as our citizenship timeline comparison explains.
Regulated funds have been the qualifying route since October 2023, when property was removed from the programme. One application can cover a spouse, dependent children and dependent parents, and for many of the families we work with, bringing everyone under a single application is the reason for applying at all. Our Portugal overview sets out each step, and our guide to evaluating a fund shortlist covers the choosing.
The three routes side by side
| Portugal Golden Visa | Portugal D7 | Italy Investor Visa | |
| Basis | €500,000 in a CMVM regulated fund | Passive income from €920 a month; no investment | One of four investments, €250,000 to €2,000,000 |
| Time in the country | 7 days a year on average | Genuine residence expected | None |
| Suits | Families whose life stays in the US | Families genuinely moving to Portugal | Families wanting approval before investing |
| Citizenship | After 10 years, while living abroad | After 10 years of residence | After 10 years genuinely lived in Italy |
The three suit three different situations. The Golden Visa is built for families whose working lives stay in the United States. The D7 assumes Portugal becomes home. Italy’s programme asks for capital rather than presence, and approves you before any money is invested.
Portugal’s D7: built for a genuine move
The D7 is Portugal’s route for people with steady passive income: pensions, dividends, rent, royalties. No investment is needed. The income floor is tied to the Portuguese minimum wage, €920 a month in 2026, and consulates generally expect half as much again for a spouse and a further 30 per cent for each dependent child.
The D7 expects you to live in Portugal. A permit can be cancelled after six consecutive months away, or eight in total across its validity, and spending more than 183 days a year there generally makes you a Portuguese tax resident. For a family genuinely moving, that is the point, and the entry cost is far lower. For a family keeping careers, schools and ageing parents in the United States, it rarely fits. Our comparison of the D7 and the Golden Visa sets out when each makes sense.
Italy’s Investor Visa: approval before investment
Italy’s programme approves you before you invest. You apply online for a Nulla Osta, a pre-approval certificate, and the government committee decides within 30 days of a complete application (Investor Visa for Italy). The money moves only after you arrive in Italy, within three months of entry.
Four investments qualify and cannot be combined: €250,000 into an innovative start-up, €500,000 into an established Italian company, €1,000,000 as a philanthropic donation, or €2,000,000 in government bonds. There is no minimum stay. For Americans, the appeal is simple: a decision before any capital is committed, and no obligation to spend a single night in Italy to keep the permit. The catch is that citizenship requires ten years genuinely lived there, with Italian at B1.
The US tax questions that apply to all three
A US citizen who takes up European residence keeps every US tax obligation. The United States taxes on citizenship rather than residence, so you continue filing federal returns wherever in the world you live, and a residence permit changes none of that (IRS).
FATCA, the Foreign Account Tax Compliance Act, also applies. Banks outside the United States report accounts held by US persons to the IRS, which in practice means extra forms when you open an account and, occasionally, a bank that would rather not take American clients. Separate annual reports apply once your foreign accounts pass US thresholds (FinCEN). None of this stops an American taking up residency, but every point in this section belongs with a US qualified tax adviser before any commitment is made, not after.
Timing, and what it means for dual residency
For most American families the goal is dual residency: a European permit held while daily life continues in the United States. Timing decides how workable that is.
In Portugal, because the citizenship count starts when the first permit is issued, processing speed matters more than it once did. AIMA has been working through a backlog, with reported waits to a first card from around a year to well beyond two, and the government has stated an aim to clear it during 2026. That is best read as an aim rather than a promise. Italy’s caveat runs the other way: there is no minimum stay, but permanent residence and citizenship both depend on genuine residence in Italy. The D7, meanwhile, runs through your Portuguese consulate in the United States, with the permit issued after you arrive, so allow months rather than weeks.
Which route fits
The Golden Visa suits a family whose daily life stays in the United States. The D7 suits a family genuinely moving to Portugal. Italy’s Investor Visa suits a family that wants approval before committing capital and no presence requirement afterwards. None is better in the abstract. Decide first how much of your life is moving to Europe, and the route usually follows.
Where to start
If you would like to talk through how these routes fit your family, get in touch. It is one call with no obligation, and we will explain how we work, including how we are paid: Elite Golden Visa receives placement or introductory fees from some funds, alongside a separate client service fee. Whichever route you choose, take independent financial, tax and legal advice before you commit.
Elite Golden Visa provides immigration consultancy services. We do not provide financial or legal advice. All legal services are delivered by independent, qualified immigration lawyers. All investment decisions should be made with independent financial advice.
This content is for informational purposes only and does not constitute financial advice or an offer to invest. Any investment carries risk, including the potential loss of capital. Past performance is not indicative of future results.
