Planning a client's relocation: the portfolio questions to settle before the move

Published 20 October 2026 by Borderfolio

A move between tax residences changes more for a portfolio than any single trade, and most of what it changes is decided by dates and conditions rather than by holdings. The useful work happens before the client leaves. This note sets out what a portfolio review should cover when a move is planned, and how Borderfolio for Advisors supports it. It is decision support for a professional conversation, not tax or legal advice.

Start with where the client has been

Relocation planning usually begins with the destination. It should begin with the history. Departure rules, trailing residence periods and eligibility for new-resident regimes often depend on how long the client lived somewhere and when they left. A client who arrived in their current country three years ago is in a different position from one who has lived there for twenty, even if the portfolio is identical.

Record each earlier residence with the dates of arrival and departure, even approximately, and the basis of residence where it matters. Those dates are the first thing a tax adviser at either end will ask for.

What the move changes for the portfolio

For a client holding listed funds, three rates move with residence:

• Withholding at source. Dividends from US-domiciled funds are withheld at the treaty rate of the client's country of residence, and only with a W-8BEN on file. A new residence can mean a different treaty rate, or no treaty at all.
• Tax at home on dividends. What the new residence charges on dividend income on top of withholding, and whether it credits tax withheld abroad.
• Capital gains. The rate on disposals while resident, and the separate question of how gains built up before arrival or departure are treated.

The first two can be estimated on the client's actual holdings. The third is rarely a single number, because it depends on when gains arose and on rules at both ends.

The questions that need a specialist

Software can compare rates. It cannot settle the questions that usually decide whether a move works out as the client expects. These are worth listing in every relocation file, even when the answer turns out to be that a question does not apply:

1. Departure. Whether leaving triggers an exit tax, a deemed disposal or continuing ties to the old residence.
2. Arrival. Whether the destination offers a new-resident regime, what it requires, when the client must apply and how long it lasts.
3. The date residence changes. Day counts, split-year treatment and the date each country treats as the change, which can differ.
4. Dual residence in the move year. Which treaty decides residence if both countries claim the client.
5. Tax-wrapped accounts. What happens to ISAs, pensions and similar wrappers once the client is no longer resident where they were opened.
6. Brokers. Whether each broker keeps serving a resident of the destination, or will ask the client to move the account.
7. Tax forms. Updating the W-8BEN and the CRS self-certification with each broker, so withholding and reporting follow the new residence.
8. Succession. Which succession and estate rules apply in the new residence.
9. Currency. Whether the client's base and spending currency change, and what that means for the portfolio's currency exposure.

Special regimes need their conditions written down

New-resident regimes are often the reason for a move, and they are conditional. Eligibility can depend on years of prior non-residence, on the client's activity, on a deadline to apply, or on time spent in the country. A review that records only the name of a regime records the least useful part. Write down the conditions as the specialist confirmed them, with the dates that matter, so the client can see what has to stay true for the regime to apply.

How Borderfolio for Advisors supports it

Each client has a Relocation tab that keeps this work in one place.

• Residence history. A timeline of earlier residences, the current one and the planned destination.
• The plan. Destination, target date, how firm the plan is, the special regime, its conditions in your words, and the rates you expect the client to pay there.
• A rate comparison. US dividend withholding, tax on dividends and capital gains tax for both residences, from Borderfolio's stored tables, with the client's own rates beside them where you set them. Any other country can be compared without saving it.
• The effect on this portfolio. The tax engine runs for the destination on the client's actual holdings and estimates the change in dividend income kept each year, per account and in total. It is labelled as an estimate and names its assumptions.
• A review checklist. The questions above, each marked open, reviewed or not applicable, with a note.

When a relocation is planned, the client's report can include a relocation section. The rate comparison and the engine's estimate print first. The regime, its conditions, the considerations you reviewed and your notes follow under an adviser-authored label, so the client and anyone they consult can see which parts are calculation and which are your professional view. Like every report, it is frozen when generated. The relocation documentation describes each screen in detail.

Where the estimate stops

Saying what a model leaves out matters more here than anywhere else:

• Only dividend income is compared, and only US-source withholding is modelled.
• Exit taxes, gains on arrival or departure and residence start dates are recorded by you, not calculated.
• The conditions of special regimes are your summary; Borderfolio holds no regime rules.
• For a US person, whose US taxation follows citizenship, the non-resident comparison is not shown at all.
• A destination outside the withholding tables is named as unsupported rather than approximated.

The comparison frames the conversation. The position in each jurisdiction should be confirmed with a qualified adviser there before the client moves.