The Global Millionaire Migration Wave of 2025: Winners, Losers, and the Shifting Wealth Map

According to Henley Private Wealth Migration Report 2025, 2025 is shaping up to be a record-breaking year for millionaire migration, with a projected 142,000 high-net-worth individuals (HNWIs) expected to relocate internationally. This unprecedented movement is not just a story of personal wealth—it’s a powerful indicator of shifting economic power, policy impacts, and evolving global investment landscapes.

UK Leads the Outflow: The “WEXIT” Phenomenon

For the first time in a decade, the UK is set to top the global leaderboard for millionaire outflows, with a staggering net loss of 16,500 HNWIs in 2025, more than double the outflow from China, which had dominated this ranking for years. This dramatic shift is being driven by recent tax reforms, including sharp hikes in capital gains and inheritance taxes, as well as new rules targeting non-domiciled residents and family wealth structures. The result? A mass exodus of wealthy individuals seeking more favorable environments, a trend some are calling “WEXIT” (wealth exit).

Europe’s Wealth Hubs: Retreat and Reinvention

The UK isn’t alone. Major EU economies France (–800), Spain (–500), and Germany (–400) are also forecast to see net millionaire losses in 2025. Even smaller markets like Ireland, Norway, and Sweden are experiencing significant outflows. The reasons are multifaceted, including tax pressures, political uncertainty, and a search for better investment climates.

But not all of Europe is losing out. Southern Europe is emerging as a new center of gravity for wealth migration:

·         Switzerland: +3,000 net inflow

·         Italy: +3,600 net inflow

·         Portugal: +1,400 net inflow

·         Greece: +1,200 net inflow

·         Monaco: +200 net inflow

Favorable tax regimes, lifestyle appeal, and active investment migration programs are drawing the wealthy southward, with cities like Milan, Lisbon, and the Athenian Riviera becoming new hotspots.

Global Winners: Where the Wealth Is Heading

The UAE retains its crown as the world’s leading wealth magnet, expecting a record net inflow of 9,800 millionaires in 2025, well ahead of the US (+7,500). The UAE’s appeal is bolstered by attractive golden visa options and its status as a stable, business-friendly hub for global investors, especially from the UK, India, Russia, Southeast Asia, and Africa.

Other notable destinations include:

·         Saudi Arabia: +2,400 (biggest riser, driven by returning nationals and international investors)

·         Singapore: +1,600 (though net inflows are at their lowest on record)

·         Australia & Canada: +1,000 each (also seeing reduced appeal)

·         Thailand: +450 (emerging as Southeast Asia’s new safe haven)

·         Hong Kong: +800 (steady inflows from Asia’s tech sector)

·         Japan: +600 (influx from China due to stability)

Caribbean and Central American countries—like Costa Rica, Panama, the Cayman Islands, and Bermuda—are also attracting record numbers of wealthy migrants, as are African nations such as Morocco, Mauritius, and Seychelles.

Global Losers: Where the Wealth Is Leaving

Beyond the UK, significant outflows are expected from:

·         China: –7,800 (lowest net loss since Covid, with more affluent Chinese choosing to stay)

·         India: –3,500 (offset by some returnees from the UK)

·         South Korea: –2,400 (political and economic turbulence)

·         Brazil: –1,200 (wealth drains to the US, Portugal, and the Caribbean)

·         Russia: –1,500

·         Vietnam: –300

·         Lebanon, Iran, Israel: Modest but concerning losses, often to Cyprus, Greece, and the UAE^[1]

The Big Picture: What Does It All Mean?

Millionaire migration is more than a trend—it’s a barometer of global confidence, policy effectiveness, and the shifting sands of economic opportunity. The fastest-growing wealth markets are often those that attract migrating millionaires or are emerging tech hubs, highlighting the crucial role of mobility in wealth creation.

As 2025 unfolds, the global map of wealth is being redrawn, one millionaire at a time.

According to CNBC the top reason why Americans abroad want to dump their U.S. citizenship include:

• Nearly 1 in 4 American expatriates say they are “seriously considering” or “planning” to ditch their U.S. citizenship, a survey from Greenback Expat Tax Services finds.  
• About 9 million U.S. citizens are living abroad, the U.S. Department of State estimates.
• More than 4 in 10 who would renounce citizenship say it’s due to the burden of filing U.S. taxes, the Greenback poll shows.

Should I Stay or Should I Go?

Need Advise on Expatriation?

 

Contact the Tax Lawyers at 

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Do Not Enter the IRS' Offshore Voluntary Disclosure Program and Then Withdraw (Without Reasonable Cause)!

According to Law360, a Michigan doctor clearly met the standard for a willful failure to file reports of foreign bank accounts, the Sixth Circuit said, confirming a lower court decision resulting in a $930,000 penalty against him.

James Kelly Jr. made multiple decisions intended to hide the fact that he did not file reports of foreign bank and financial accounts, or FBARs, for his holdings in Swiss banks, the appeals court said in an order issued February 8, 2024, upholding a summary judgment ruling in favor of the U.S. government.

"The undisputed facts show that Kelly knew about his foreign account, undertook considerable efforts to keep it secret, did not consult with any professionals about his tax obligations, and then failed to ensure that the FBARs were submitted after learning he had not met these reporting requirements in the past," the court said. 

"Given All Of This, Kelly's Failure To Satisfy His FBAR Requirements For The Years 2013, 2014, And 2015
Was A Willful Violation Of The Bank Secrecy Act."

The government alleged in court documents that Kelly opened an account at Finter Bank in Switzerland in 2008 when he left the U.S. to avoid a criminal inquiry. The bank advised him to consider joining the IRS' Offshore Voluntary Disclosure Program, the U.S. said.

Kelly joined the IRS' Offshore Voluntary Disclosure Program, but eventually stopped cooperating with the agency, and in 2015, he transferred the funds to Bank Alpinum AG in Liechtenstein, according to the government.

The U.S. requested summary judgment against Kelly in 2022, arguing he hadn't responded to a claim for $930,000 in penalties for failing to report his Swiss bank account to the Internal Revenue Service. A federal district court granted that request in 2023.

The Sixth Circuit concurred. It held that a willful violation includes both knowing and reckless violations. Every other circuit that has addressed the issue has adopted this standard, it said.

There was ample evidence that Kelly willfully failed to file his FBARs, it said. 

• He designated his account as numbered so his name would not appear on statements, the court said, 
• he had the bank retain correspondence. 
• Kelly did not take steps to comply with his reporting obligations until his bank told him it would take steps to notify U.S. authorities, the court said. 
• He did not consult an attorney or tax expert and 
• Still did not submit FBARs even after joining the voluntary disclosure program, it said.

 Do You Have Undeclared Offshore Income?

 

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Tax Court Rejects Jury Trial for Conservation Easement Fraud Penalties

Silver Moss Properties et al. v. Commissioner, docket number 10646-21, is a pivotal Tax Court case addressing a partnership-level dispute under TEFRA involving Silver Moss Properties, LLC. The controversy centered on the claim of a conservation easement deduction taken for property contributed to the Atlantic Coast Conservancy and raised significant procedural and constitutional questions about the imposition of civil fraud penalties.

Conservation Easement Deduction Challenge

The IRS challenged Silver Moss Properties, LLC’s deduction for its conservation easement, asserting that the claimed deduction was improper based on valuation, legal substance, and compliance issues. The partnership structure meant the dispute was adjudicated at the entity level under TEFRA, with all affected partners bound by the final Tax Court determination.

Civil Fraud Penalties and Jury Trial Rights

Central to the proceeding was Silver Moss Properties’ attempt to invoke the Seventh Amendment right to a jury trial for civil fraud penalties, following the Supreme Court’s decision in SEC v. Jarkesy, which held that individuals facing civil penalties from an administrative agency are entitled to a jury trial. The taxpayer argued that the Tax Court, as a non-Article III court, cannot constitutionally impose such penalties without affording a jury trial. This argument was supported by amicus briefs filed on behalf of the Center for Taxpayer Rights and advocated by prominent tax litigators.

Tax Court Ruling

The Tax Court rejected Silver Moss’s request for a jury trial, distinguishing tax penalty proceedings from the context of Jarkesy and affirming its jurisdiction to adjudicate civil fraud penalties. The court reasoned that the IRS’s process does not implicate the same Seventh Amendment concerns, as tax proceedings historically have been conducted in administrative or judicial forums without juries. Accordingly, motions for partial summary judgment on the constitutional grounds were denied, and the Tax Court retained authority over the penalty dispute.

Procedural and Wider Impact

This decision is significant for partnerships, conservation easement cases, and taxpayers at risk of civil fraud penalties. The outcome underscores the limits of jury trial protections in tax controversy, clarifies the scope of Tax Court authority, and suggests that efforts to extend the Jarkesy rationale to tax fraud penalty cases will require further appellate consideration. 

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Sources: 

1.       https://www.casemine.com/judgement/us/6294569f714d58f23955e74b 

2.      https://www.leagle.com/decision/intco20250821i34 

3.      https://kostelanetz.com/kostelanetz-files-amicus-briefs-challenge-tax-fraud-penalties/ 

4.      https://www.vitallaw.com/news/llc-not-entitled-to-jury-trial-in-civil-fraud-proceeding-court-retains-jurisdiction-to-adjudicate-penalty-silver-moss-properties-llc-tc/ftd01acf3ebbc49cb41be8aac79d524b0eeb0

5.       http://federaltaxprocedure.blogspot.com/2025/08/tax-court-rejects-sces-hail-mary.html

6.      https://www.law360.com/articles/2379857

7.       https://www.casemine.com/judgement/us/65b5d84d3cd82457c68a7aeb/amp

8.      https://law.justia.com/cases/federal/appellate-courts/F2/758/211/63739/

9.      https://www.currentfederaltaxdevelopments.com

10.   https://taishofflaw.com/2023/09/20/the-tefra-two-step/

11.    https://www.leagle.com/decisions/browse/latest/Us Tax Court

12.   https://www.casemine.com/judgement/us/6294569f714d58f23955e74b?target=amp_similar

13.   http://federaltaxprocedure.blogspot.com/2025/08/tax-court-rejects-sces-hail-mary.html

14.   https://www.vitallaw.com/news/llc-not-entitled-to-jury-trial-in-civil-fraud-proceeding-court-retains-jurisdiction-to-adjudicate-penalty-silver-moss-properties-llc-tc/ftd01acf3ebbc49cb41be8aac79d524b0eeb0

15.    https://www.law360.com/articles/2379857

16.   http://federaltaxprocedure.blogspot.com

17.    https://taishofflaw.com/2023/09/20/the-tefra-two-step/

18.   https://www.casemine.com/judgement/us/65b5d84d3cd82457c68a7aeb/amp

19.   https://www.casemine.com/judgement/us/6294569f714d58f23955e74b

20.  https://taishofflaw.com

20. https://www.courtlistener.com/opinion/4561059/moss-v-commr/

TIGTA Concluded That The IRS Wrongly Terminated Probationary Employees But They Still May Be Terminated

On July 1, 2025 we posted Supreme Court Limits Nationwide Injunctions: What You Need to Know & Impact on IRS Firings where we discussed that the Supreme Court Limited Nationwide Injunctions and thereby eliminated the District Court injunction of fired IRS employees, with the injunction only appling to those individuals who are parties to the case and the remaining 7000 workers can be fired.

Now TIGTA has released their Report Number: 2025-IE-R028 stating that there have been ensuing court challenges since notices were sent to probationary employees in February 2025 terminating their employment. Subsequently, IRS and Treasury Department leadership decided that all 7,315 probationary employees sent termination notices must return to full work status by May 2025. These employees were notified of their mandatory return date along with onboarding instructions. These employees had previously been placed on administrative leave after court rulings in March 2025. Our evaluation focused on the actions and processes that the IRS followed when it sent termination notices in February and March 2025 to probationary employees.

The IRS identified more than 16,000 employees who were still in their probationary period. After exempting employees who were either deemed essential personnel for tax filing season, had appeal rights, were involved in law enforcement, or were military spouses, the IRS issued termination letters to 7,315 probationary employees. The time between identifying employees and issuing termination notices was 29 days. All probationary employees received the same letter that cited performance as a reason for termination. We confirmed that nearly all the terminated probationary employees either did not have a performance rating on record or were rated as Fully Successful or better. We determined that 51 percent had no performance rating of record. For the remaining 49 percent, we determined that 3,251 (90 percent) had a “Fully Successful” rating, and 305 (8 percent) had an “Outstanding” or “Exceeded Fully Successful” rating. As a result, we conclude that the IRS did not consider individual employee performance when terminating probationary employees.

Prior to the termination notices being sent, senior IRS officials refused to sign the notices and raised concerns that many of these employees did not have documented performance issues. Despite these concerns, the IRS Human Capital Office sent the notices. However, the IRS did not correctly identify all mission critical services and employees when it identified probationary employees who were exempt from termination. After sending out termination notices, the IRS later attempted to rehire a small number of employees who had incorrectly been identified for termination.

In July 2025, the U.S. Supreme Court stayed the federal court’s prohibition on covered agencies implementing Agency Reduction in Force and Reorganization Plans and issuing or executing reduction in force (RIF) notices. At the time we published this report, it is unclear whether any probationary employees will remain reinstated or be terminated in a future large-scale RIF.

Have an IRS Tax Problem? 

    

Contact the Tax Lawyers at 

Marini & Associates, P.A. 

 

 

for a FREE Tax HELP contact us at:

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or Toll Free at 888-8TaxAid (888) 882-9243