Global Mobility and Residency Planning for Property-Owning Families

For an internationally mobile family, three sets of decisions interact at the structural level: where the family is tax-resident, where they spend physical time, and where the assets sit. Decisions in any one of these silos rarely make sense in isolation. They should be planned together, ideally with coordinated counsel in each affected jurisdiction. This essay sets out the variables and walks through several common configurations among Shibui's client base.

The variables

• Tax residence — typically determined by physical presence (often 183 days as a rough threshold but with significant variation by jurisdiction) plus tie-breaker tests under double-tax treaties. Some jurisdictions (UK, Spain, US) have more intrusive residency tests than others.
• Citizenship — fixed for many, increasingly multiple for globally mobile families. The US is the only major jurisdiction taxing citizenship rather than residence — a unique structural variable.
• Asset situs — where the property and other assets are legally located, which determines estate and gift tax exposure independent of where the family lives.
• School and family base — often the most operationally constraining variable. School calendars, university preparation, and the location of the family's social anchor frequently drive everything else.

Common configurations

What we typically advise on first

We tend to start with tax residence (the most consequential and hardest to reverse), then asset situs (which can be restructured but with friction), then physical-time planning (which is most flexible). The order matters: structuring assets to a Spanish-resident family before they have decided whether to commit to Spanish residence creates wasted set-up cost when the family relocates two years later.