From United States to Malta

Leaving United States

• Citizenship-based taxation. US citizens are taxed on worldwide income wherever they live. Moving abroad does not end US tax filing; only renouncing citizenship does. Foreign earned income exclusion and foreign tax credits can reduce the bill.
• Green card test. Lawful permanent residents (green card holders) are US tax residents for any part of the year they hold the card, regardless of days spent in the US.
• Substantial presence test. You are resident if present at least 31 days this year and at least 183 days counting all days this year, one third of last year's days and one sixth of the year before.

Rules that can follow you after leaving

• Expatriation tax on renouncing citizenship or a long-held green card. Citizens who renounce, and green card holders who held the card in at least 8 of the last 15 years, may be covered expatriates and pay a mark-to-market exit tax.
• Tax on gifts and bequests from covered expatriates. US persons who receive gifts or inheritances from a covered expatriate pay tax on them at the highest gift or estate tax rate (currently 40%), with no time limit.

Exit tax in United States

Expatriation tax (IRC section 877A)

• Applies to citizens who renounce and long-term residents (green card in at least 8 of the last 15 years) who give it up.
• Covered expatriate if ANY of: net worth of USD 2 million or more on the expatriation date; average annual net income tax liability for the previous 5 years above USD 211,000 (2026 expatriations; USD 206,000 for 2025); or failure to certify 5 years of tax compliance on Form 8854.
• Limited exceptions for certain dual citizens from birth and people who renounce before age 18 and a half.

Mark-to-market: all worldwide assets are treated as sold at fair market value the day before expatriation. Net gain above the exclusion amount (USD 910,000 for 2026; USD 890,000 for 2025) is taxed at normal capital gains or income tax rates. Deferred compensation, tax-deferred accounts (IRAs) and interests in non-grantor trusts have special rules.

Exit tax → · Am I still resident? →

Arriving in Malta

Personal income: 15% remitted · Company tax: 5–35%

Global Residence Programme with a home bought or rented above a minimum.

Do not spend more than 183 days in any other country.

Only income brought into Malta is taxed, at 15%, with a €15,000 yearly minimum. Company tax 35% with refunds that bring it close to 5%.