How to Structure CBI When You Have 3+ Citizenship Jurisdictions

Wealth transfer across generations is complex. Add multiple citizenship jurisdictions to the equation, and you're facing a labyrinth of tax laws, inheritance regulations, and succession planning frameworks that few advisors can navigate with confidence. For high-net-worth families considering citizenship by investment as part of their broader wealth architecture, understanding how to structure multigenerational transitions isn't optional—it's essential to protecting decades of accumulated capital and ensuring your family's security across borders.

The reality is that most families pursuing second citizenship focus on the immediate benefits: visa-free travel, tax optimization for the applicant, and portfolio diversification. What they often overlook is what happens when the founder passes away. Without proper planning, your carefully constructed CBI strategy can unravel, leaving heirs in legal uncertainty, facing double taxation, unexpected capital gains taxes, and competing claims from multiple jurisdictions—each believing they have the right to tax your estate.

The Fundamental Problem: Citizenship Doesn't Equal Tax Residency

The first mistake most high-net-worth individuals make is conflating citizenship with tax residency. They are not the same thing.

Your citizenship determines your nationality, your right to a passport, and your legal standing to reside in a country. Your tax residency, by contrast, is determined by where you physically reside, where your economic interests lie, and where you maintain a permanent home. A person can hold citizenship in St. Lucia while being tax resident in Switzerland. Another person might be a US citizen (taxed on worldwide income regardless of residence) while holding a Dominica passport and residing in Portugal.

When you die, your heirs don't inherit your citizenship status the same way they inherit your assets. Instead, they inherit two separate legal challenges: first, determining which country's tax laws govern the distribution of your estate, and second, figuring out where each heir's own tax residency obligations begin and end. If you've structured your wealth across multiple jurisdictions—real estate in Turkey, a business in the US, investments in a low-tax Caribbean jurisdiction, and residency in Europe—your estate administration becomes a multi-jurisdictional nightmare.

Consider this scenario: You obtain St. Lucia citizenship through a $240,000 donation. You also maintain residency in Portugal (for EU access), conduct business in the United States, and hold significant real estate in the UK. When you die, which country's inheritance laws apply? All of them, potentially. Your US business interests trigger US estate tax (even if your heirs are non-US citizens). Your UK property is subject to UK inheritance rules. Your Portuguese residency may create tax complications there. And your St. Lucia citizenship—while useful for travel—provides little comfort to your heirs trying to untangle this web.

Designing a Multigenerational Succession Framework

The solution lies in intentional, coordinated planning that treats your citizenship strategy as one component of a larger wealth transfer architecture, not an isolated transaction.

Start by mapping your family's complete asset footprint across jurisdictions. This means documenting not just where your assets physically exist, but where they're legally domiciled, which country's courts would have jurisdiction in a dispute, and what tax regime governs their sale or transfer. A professional wealth advisor should work with your tax counsel and immigration attorney to create what's called a "jurisdiction dependency chart"—a visual map showing which assets are exposed to which legal systems and tax authorities.

Next, you need to decide whether your CBI choice supports or complicates your broader succession plan. For example, if your family is primarily UK-based with aspirations for your children to attend Swiss boarding schools and eventually manage a family office in Luxembourg, acquiring St. Lucia citizenship might be an excellent Plan B for geopolitical risk mitigation, but it shouldn't become the centerpiece of your wealth transfer strategy. The tail shouldn't wag the dog.

Conversely, if your family is genuinely dispersed across multiple continents—one child running a tech startup in Singapore, another managing family real estate in Dubai, a third studying in the US—then a deliberate multi-citizenship strategy actually simplifies certain elements of succession planning. Your heirs can hold passports that align with their actual economic activity, reducing conflicts between their citizenship, residency, and tax obligations.

The key is intentionality. Too many families acquire CBI passports reactively, without asking how the decision cascades through the next generation's life. A second citizenship acquired at age 55 for tax reasons might create complications for your 25-year-old daughter's career visa sponsorship in Canada, or your son's security clearance application if he works for a government contractor. These aren't dealbreakers—but they need to be anticipated, documented, and addressed in your family governance structure.

The Citizenship Inheritance Question: What Actually Passes to Your Heirs?

Many CBI programs explicitly allow citizenship to pass to future generations, but the rules vary significantly by jurisdiction and by heir status.

In most Caribbean CBI programs, your children (if born to you after you obtain citizenship) automatically inherit your citizenship. This is a major advantage. Your daughter born after you acquire a St. Lucia passport is a St. Lucia citizen from birth, without requiring additional investment or due diligence. She can pass that citizenship to her children, creating a multi-generational benefit from your single investment.

However, if your children were born before you obtained CBI citizenship—or if they're adult children—the rules change. Some programs allow adult children to be included in your application at the time you apply, but require them to undergo their own due diligence and often charge substantial fees. Other programs charge higher fees for adult dependents than for minor children. A few programs don't allow adult children at all.

This creates a practical planning issue: should you time your CBI application before or after having children? Some families deliberately time citizenship acquisition before childbirth specifically to pass automatic citizenship to future generations. Others already have adult children and must decide whether the cost of including them ($30,000-$50,000+ per adult) is worth the benefit.

Then there's the more sensitive question: what if your family structure is complex? If you have children from multiple relationships, or if you later remarry and acquire stepchildren, how does the CBI citizenship pass? Does it depend on blood relation or legal recognition? Different jurisdictions have different rules, and these legal nuances can create conflicts between heirs, between the citizenship authority and your estate, and between your family's wishes and the law's prescriptions.

Austria's program, for example, is far more restrictive. Citizenship doesn't automatically pass to children. Instead, your heirs would need to make their own substantial contribution (in the millions of euros) to qualify for citizenship. This limits multigenerational planning benefits and means Austria CBI is better suited to individuals focused on personal security and mobility, not family legacy.

Conversely, Caribbean programs like Dominica and St. Lucia are specifically designed with multigenerational planning in mind. Children born to citizens automatically inherit citizenship. The programs actively market this as a legacy benefit—acquire citizenship now, secure your children's future for life.

Building a Family Governance Structure for Multi-Jurisdiction Wealth

Once you've mapped your jurisdictions and understood the citizenship inheritance rules, the next step is building a family governance framework that anticipates and addresses multigenerational complications.

This typically involves creating a family constitution or family governance document—a non-binding but important agreement among family members about how decisions are made regarding assets, citizenship, tax residency, and business continuity. The document should address what happens if a family member faces sanctions, criminal charges, or public scandal that could jeopardize the family's CBI status (a real issue, as noted in discussions about CBI and extradition implications). It should clarify which family members have authority to make decisions about restructuring assets or changing tax residency, and what consensus is required.

For families with significant wealth and multiple citizenship jurisdictions, many establish a family office—a dedicated team of advisors (lawyers, accountants, investment managers) who work together to coordinate decisions across all jurisdictions. The family office maintains updated documentation on which family members hold which citizenships, what tax residencies are in effect, where assets are domiciled, and what the succession plan looks like. When a family member dies, the family office coordinates with local courts and tax authorities to execute the succession plan with minimal disruption.

Some ultra-high-net-worth families also structure their wealth into a holding company domiciled in a neutral jurisdiction (like Luxembourg or the Netherlands), which owns operating companies in various countries. This doesn't eliminate tax obligations, but it centralizes control and simplifies certain aspects of succession. When the founder dies, the transfer of the holding company's shares is cleaner than transferring individual assets across multiple jurisdictions.

The practical reality is that most families won't need this level of sophistication. But families with $50+ million in assets, significant international business operations, or real estate across multiple continents absolutely will. The cost of setting up proper structures is far less than the cost of resolving conflicts and tax complications after the founder's death.

Practical Implementation: A Three-Jurisdiction Example

Let's walk through a realistic scenario to illustrate how this works in practice.

You're a 48-year-old businesswoman with $15 million in wealth. You're domiciled in the UK (where you're a citizen), but you operate an e-commerce business with operations in Singapore and manage real estate investments in Dubai. You have two children: a 22-year-old daughter studying in the US, and a 19-year-old son who has just started a tech startup in Singapore.

Your current tax situation is complicated. As a UK citizen, you're subject to UK tax on UK-sourced income and on worldwide income if you remain UK tax resident (more than 90 days/year in the UK). Your daughter, as a US student, will eventually be subject to US tax as a US citizen on worldwide income. Your son, while in Singapore, is establishing tax residency there and must manage his Singapore tax obligations on his startup income.

You're considering acquiring Grenada CBI citizenship for several reasons: the E-2 visa treaty gives you potential US residency options, the passport offers strong mobility, and you want a Plan B jurisdiction if UK residency becomes impractical.

Here's how a structured plan would look:

Year 1: Acquire Grenada citizenship through a $230,000 donation. Your children are not included in the application (they're adults and don't require inclusion for your own Plan B strategy).

Year 1-2: Family governance setup – You establish a family trust domiciled in the UK that holds ownership of your UK real estate and business operating company. This clarifies succession and provides some flexibility for your heirs' future tax planning.

Year 2-3: Children's decision points – Your daughter, having graduated from university and become a US tax resident, makes an independent decision: does she want to acquire Grenada citizenship herself? The cost would be $230,000 + due diligence fees (roughly $50,000 total). The benefit: visa-free access to 140+ destinations, the E-2 visa option if she wants to relocate to the US, and potential tax planning benefits. She decides it's worthwhile and applies separately.

Your son, based in Singapore, decides to focus on Singapore tax residency and doesn't pursue CBI. He's building a business there and doesn't need a second citizenship at this stage.

Year 5: Scenario planning for your death – You work with your tax advisor to model what happens to your estate if you die today. Your UK assets trigger UK inheritance tax. Your US-source income from your daughter's education trust (held in the UK) is clean. Your daughter's US tax liability depends on her future income, not your estate. Your son's Singapore operations are separate legal entities in which your personal estate has no claim. The scenario is manageable, assuming your UK will is clear and your US affairs are documented.

But you also model an alternative scenario: what if you move to Dubai permanently in 10 years for tax residency there? Then your Grenada citizenship becomes your backup (if UAE residency rules change), and your daughter's Grenada citizenship creates additional flexibility for her if she wants to relocate to the Caribbean or access US visa options. You've built optionality without forcing any of your heirs into a specific path.

Year 20: Intergenerational transfer – When you eventually pass away, your UK estate is administered under UK law. Your daughter inherits a portion of your wealth. She may be tempted to change her tax residency to Grenada (as a Grenada citizen with no worldwide income tax for non-residents) to minimize her tax burden on inheritance gains. She can legally do so, though she'd need to manage her US tax obligations as a US citizen separately. Your son inherits his portion and continues building his Singapore business.

Critically, because you planned ahead, your heirs aren't scrambling to figure out tax residency, citizenship status, and asset control under time pressure. The succession is clear. The citizenship options are available if needed. The family governance structure helps coordinate decisions.

The Pitfalls to Avoid

Several common mistakes derail multigenerational CBI planning:

First, failing to disclose all existing citizenships and tax residencies. CBI due diligence is strict. If you fail to disclose that you're a US citizen, or that you maintain significant assets in another jurisdiction, and this is later discovered, your citizenship can be revoked. Your heirs inherit a revoked citizenship, which is worthless.

Second, overestimating the tax benefits. Many investors acquire CBI expecting immediate, dramatic tax savings. The reality is more nuanced. A second citizenship doesn't eliminate your home country's tax obligations. US citizens still owe US tax on worldwide income. UK citizens still owe UK tax. CBI offers flexibility in planning, but not magic. For your heirs, understanding the true tax implications of citizenship by investment structures is critical before they make decisions based on inherited citizenship.

Third, acquiring CBI without a clear purpose or integration into broader wealth strategy. If you're acquiring a Caribbean CBI passport as pure optionality, that's legitimate. But if you're acquiring it because you expect your heirs to eventually relocate to that jurisdiction, make sure that assumption is sound. Don't impose a citizenship on your heirs that doesn't align with their life plans.

Fourth, ignoring the reputational and compliance risks. If your jurisdiction of choice faces regulatory scrutiny, sanctions concerns, or loses visa-free access to key countries, the value of the citizenship declines rapidly. Your heirs inherit an asset that's becoming less useful. For context on how regulatory and legal pressures affect CBI programs, reviewing emerging citizenship by investment frameworks and regulatory environments can help you anticipate risks.

Fifth, failing to update your succession plan when circumstances change. CBI programs evolve. Tax laws change. Your family's situation shifts. Your wealth structure expands or contracts. A succession plan written in 2020 may be partially obsolete by 2026. Annual or biennial reviews with your tax and immigration advisors are essential.

Conclusion: CBI as One Piece of a Larger Puzzle

Citizenship by investment isn't a standalone wealth transfer tool. It's one component of a comprehensive succession strategy that should include wills, trusts, tax residency optimization, asset protection structures, and family governance.

For families with wealth spread across multiple jurisdictions and heirs with different economic interests, CBI programs like Dominica and St. Lucia can add significant value—particularly because citizenship automatically passes to future generations. The optionality created by a second passport can open doors for your heirs that would otherwise require visas, residency applications, or costly relocation expenses.

But that value only materializes if the CBI acquisition is intentional, integrated into your broader plan, and regularly reviewed and updated as circumstances change.

The cost of proper planning—working with tax counsel, immigration attorneys, and wealth advisors to design a coherent multigenerational strategy—is often 10-20% of the total CBI investment plus setup costs. It's a worthwhile expense. The alternative is leaving your heirs to untangle a complex web of citizenship, tax, and asset issues under time pressure and emotional stress.

Start with your end goal: what does wealth transfer look like for your family across generations and jurisdictions? Then work backward to determine whether CBI belongs in that picture, and if so, which program aligns with your heirs' likely future needs and circumstances.

That's how you transform CBI from a personal tax planning tactic into a multigenerational wealth architecture that actually serves your family's long-term security and optionality.