Why Americans Are Seeking European Citizenship
Over the past decade, there has been a marked increase in the number of U.S. citizens establishing residence or citizenship in Europe. The motivations range from lifestyle and education to succession planning and geopolitical diversification.
Europe offers a unique blend of benefits:
- Schengen mobility allows visa-free travel across most of Europe.
- Rule of law and political stability create secure environments for global families.
- Access to education and healthcare in public and private systems across EU states.
- High quality of life with diverse cultural and linguistic experiences.
- Family security and estate continuity, supported by robust legal systems and private international law frameworks.
For many Americans, acquiring a European residence or citizenship is not a matter of abandoning U.S. nationality but of expanding global optionality — ensuring the ability to live, study, or retire abroad while retaining transatlantic access.
Understanding Citizenship and Residence Options
Citizenship by Descent
For Americans with ancestral roots in Europe, citizenship by descent is often the most straightforward path. Countries like Ireland, Italy, and Poland allow individuals to reclaim nationality through a parent, grandparent, or even earlier ancestor, provided the family line was never broken by renunciation.
Eligibility depends on proof of lineage and documentary evidence such as birth, marriage, and naturalisation certificates. While the process can be document-intensive, it offers a cost-effective and permanent path to EU citizenship with full rights to reside, work, and study in all Member States.
Citizenship by descent appeals especially to second- and third-generation Americans seeking to reconnect with their European heritage while unlocking mobility and lifestyle benefits for future generations.
Citizenship by Naturalisation and Merit
Where ancestry does not apply, Americans may pursue citizenship through residence and contribution. Under Malta’s Citizenship by Merit Regulations (2025), applicants may apply for citizenship after a minimum eight-month period of legal residence and a demonstrated contribution to the country’s national, philanthropic, or cultural development.
This model replaces older transactional approaches with a merit-based framework consistent with EU law and Malta’s Vision 2050, which emphasises transparency, service, and long-term commitment to the Maltese community.
Qualifying contributions may include:
- Supporting philanthropic or educational initiatives in Malta.
- Establishing or expanding a local business or research initiative contributing to innovation or sustainability.
- Participating in public interest projects aligned with national priorities.
“Citizenship may be granted to individuals who demonstrate a genuine link and a measurable contribution to the Republic of Malta.”
— Maltese Citizenship by Merit Regulations, 2025
This approach ensures that citizenship remains a recognition of genuine connection and service rather than a transaction — a significant evolution in European citizenship policy.
Residence leading to Citizenship
Many U.S. nationals prefer to establish European residence first, allowing them to experience life abroad before committing to full naturalisation. Several countries offer residence programmes that provide long-term stability and eligibility for citizenship after several years:
- Malta Permanent Residence Programme (MPRP): Permanent residence from the outset, providing Schengen mobility and family inclusion.
- Portugal Golden Visa: A flexible route requiring limited physical presence, leading to citizenship after five years of residence and integration.
- Greece Golden Visa: Residence through property investment, renewable every five years, ideal for holiday-home investors.
- Cyprus Permanent Residence: Property-based indefinite residence, providing legal stability and strategic access to Europe.
Each framework differs in eligibility, tax implications, and naturalisation timelines, and the right choice depends on personal circumstances — lifestyle, family structure, and long-term intent.
Comparing European Citizenship and Residence Routes
Although both citizenship and residence offer European mobility, they differ significantly in scope and permanence.
Citizenship grants:
- Full EU citizenship rights, including work and establishment freedoms across all Member States.
- Permanent, inheritable status.
- Access to EU political and consular rights.
Residence offers:
- Legal right to reside and travel within the Schengen Zone.
- Retained foreign citizenship.
- Possibility of citizenship after several years, subject to residence and integration tests.
For many Americans, beginning with a residence-by-investment or residence-by-merit pathway provides flexibility while preserving control over tax and compliance considerations. Over time, these routes can be adapted toward citizenship once physical presence and integration requirements are met.
Strategic Considerations for U.S. Citizens
When evaluating European citizenship or residence opportunities, U.S. nationals should assess:
Tax implications
The United States taxes its citizens on worldwide income, regardless of residence. Before relocating or naturalising, clients should obtain coordinated U.S.–EU tax advice addressing FATCA, CRS, and dual reporting obligations.
Dual nationality and legal compatibility
Most European states permit dual citizenship, but applicants must verify recognition under both jurisdictions to prevent inadvertent renunciation or duplication.
Succession and family planning
European succession rules (notably under Regulation 650/2012) can impact estate planning for dual residents. Structuring through trusts, foundations, or wills aligned with EU law helps preserve family control and privacy.
Family eligibility
Most residence and citizenship programmes permit inclusion of spouses, children under 25, and dependent parents. For multigenerational planning, the inclusiveness of dependants is a key differentiator.
Lifestyle and strategic access
Beyond law and taxation, quality of life, education systems, healthcare, and business ecosystems should guide decision-making. For U.S. families, relocation often combines lifestyle preference with strategic investment diversification.
How Our Immigration and Citizenship Lawyers Can Help You
Our Immigration and Citizenship Lawyers assist American families, entrepreneurs, and global investors in navigating the European residence and citizenship landscape.
We provide:
- Comparative legal analysis of the available EU residence and citizenship frameworks for U.S. nationals.
- Cross-border structuring for clients with business, family, or philanthropic interests spanning multiple jurisdictions.
- Integrated legal, tax, and compliance advice, ensuring alignment with U.S. reporting requirements.
- Application and representation services for Malta, Portugal, Greece, Cyprus, and Italy.
- Strategic guidance on long-term relocation, dual citizenship, and future citizenship eligibility.
Our cross-disciplinary approach ensures every residence or citizenship strategy is sustainable, compliant, and aligned with your family’s legacy and business objectives.
About the Author
Dr Jean-Philippe Chetcuti is a Maltese lawyer and founding partner of CCLEX.With over 25 years’ experience in international tax, immigration, and private client law, he has advised HNW and UHNW families, entrepreneurs, and family offices on residence, citizenship, and cross-border structuring within the European Union and beyond.Dr Chetcuti has served as Chairman of STEP Malta, contributed to STEP Journal and Investor Migration Daily, and frequently lectures on EU residence and citizenship law and international tax planning.He is recognised for his leadership in shaping Malta’s immigration and private client frameworks and for his practical, multidisciplinary approach integrating legal, tax, and relocation strategy.