UAE Setup · For US Citizens & GC Holders
UAE setup for Americans.
US persons (citizens and Green Card holders) carry global US tax obligations no matter where they live. UAE structuring requires careful US-side planning.
Key US-specific considerations
- Worldwide tax — US citizens and Green Card holders are taxed on worldwide income regardless of residency. Becoming UAE-resident does not end US tax obligations.
- FATCA — UAE banks ask US-person status and report to IRS. Disclose accurately at onboarding.
- GILTI / Subpart F — US shareholders of controlled foreign corporations (CFCs) face current-tax inclusion on certain UAE profits.
- Form 5471 filing for US persons owning 10%+ of foreign corporations. Substantial penalties for non-filing.
- FBAR (FinCEN 114) for any US person with foreign accounts over USD 10,000 aggregate.
- Foreign Earned Income Exclusion — up to USD 130,000 (2026) excludable if you meet bona fide residence or physical presence test. Useful but requires careful structuring.
Recommended structures
We coordinate with US tax counsel on the right structure. Common patterns: Delaware C-Corp at the top for stock options + UAE Free Zone operating subsidiary. Or QEF election on PFIC investments. Renouncing US citizenship is a separate, irrevocable decision with exit-tax consequences.