Tax Residency Statistics for Expats 2026

By John from the Nomad TeamMay 7, 2026
Tax Residency Statistics for Expats 2026

Roughly 9 million Americans live abroad per State Department estimates, FinCEN received approximately 1.5 million FBAR filings in fiscal year 2023, and the IRS Statistics of Income shows around 471,000 Form 2555 (FEIE) filings excluding about $36 billion in foreign earned income for tax year 2021. The Treasury Federal Register published 5,565 expatriations in 2024. Portugal's old NHR regime enrolled over 89,000 residents before closing in 2024. This report compiles 12 verified data points from the IRS, FinCEN, US Treasury, HMRC, OECD, and national tax authorities for expats and digital nomads in 2026.

Tax residency is the most expensive thing a digital nomad or expat can get wrong, and the least tracked. The numbers below come from primary government sources wherever possible: IRS Statistics of Income, the Treasury Department's quarterly Federal Register publications, FinCEN BSA data, HMRC residency statistics, and Spain's Agencia Tributaria.

This post covers the US expat population, federal tax compliance volumes (FEIE, FBAR), expatriation trends, take-up rates of major expat tax regimes (Portugal NHR/IFICI, Spain's Beckham Law, Italy's impatriate regime, UAE tax residency certificates), and the "stateless tax resident" trap that catches more nomads each year.

TL;DR: Top 5 headline stats for 2026

  1. The US State Department estimates approximately 9 million US citizens live abroad, though no agency tracks the figure precisely (FVAP 2022 Analysis).
  2. FinCEN received roughly 1.5 million FBAR filings in fiscal year 2023, required of US persons with $10,000+ in foreign accounts (FinCEN Year in Review FY2023).
  3. Treasury published 5,565 expatriations in calendar year 2024 under IRC Section 6039G (Federal Register).
  4. About 471,000 Form 2555 filers excluded $36 billion of foreign earned income in tax year 2021, the latest published data (IRS SOI).
  5. Portugal's NHR regime enrolled over 89,000 residents between 2009 and 2024, when it closed to new applicants and was replaced by the narrower IFICI / NHR 2.0 (Reuters, 2024).

Why these numbers matter in 2026

Expat tax residency moved from a niche concern for retirees to a mainstream problem for digital nomads and remote employees. FinCEN's FBAR enforcement has tightened. The OECD's Common Reporting Standard means foreign banks routinely send account data back to your home country. Several expat-friendly regimes (Portugal NHR, Italy impatriate) have been rewritten in the last 24 months as host countries respond to housing pressure and political backlash.

The data below shows three things: the population subject to these rules is large, formal compliance lags behavior, and "tax-non-resident-anywhere" is a real audit category. The numbers come from federal filings, not vendor surveys.

1. Approximately 9 million US citizens live abroad

The US Department of State estimates approximately 9 million American citizens reside outside the United States, a figure cited in State Department travel publications and Federal Voting Assistance Program research. The 9 million figure includes private citizens, military, diplomats, and dual nationals.

The exact number is unknown. The US does not require expats to register with consulates, and the Census Bureau does not enumerate citizens abroad. The 9 million estimate is built from consular data, IRS filing records, and FVAP modeling. FVAP's most recent Overseas Citizen Population Analysis estimated roughly 4.4 million voting-age civilian US citizens abroad in 2022, excluding military and minor children.

For context, that population is larger than the resident populations of all but the 13 most populous US states. The US tax filing base abroad is genuinely large.

Source: FVAP 2022 Overseas Citizen Population Analysis

2. Around 1.5 million FBAR filings in fiscal year 2023

The Financial Crimes Enforcement Network (FinCEN) reports approximately 1.5 million FBAR (FinCEN Form 114) filings during fiscal year 2023. The FBAR is required of any US person whose aggregate foreign financial accounts exceeded $10,000 at any point in the calendar year.

FinCEN's annual reporting volume has grown as FATCA and CRS data sharing flushed previously unreported accounts into the system. Penalties for willful non-filing reach the greater of $100,000 or 50% of the account balance, per violation, per year. Non-willful penalties are capped per form rather than per account after the Supreme Court's 2023 Bittner decision.

For nomads with foreign brokerage, payment platform, or local checking accounts, the threshold triggers easily. FBAR is separate from Form 8938 (FATCA), which has higher thresholds and goes with the 1040.

Source: FinCEN Year in Review FY2023

3. About 471,000 Form 2555 filers excluded $36 billion in foreign earned income

According to the IRS Statistics of Income (SOI) division, approximately 471,000 individual taxpayers filed Form 2555 (Foreign Earned Income Exclusion) for tax year 2021, the latest year of fully published SOI individual return data. Those filers excluded approximately $36 billion in foreign earned income under IRC Section 911.

The FEIE for 2024 caps exclusion at $126,500 per qualifying individual, adjusted annually for inflation. Taxpayers must meet either the bona fide residence test or the 330-day physical presence test in a 12-month period. The FEIE does not exempt a US citizen from filing; it reduces taxable income on a return that still must be filed.

The number of filers has been stable in the 450,000 to 500,000 range for several years. That likely understates the eligible population, because many Americans abroad use foreign tax credits (Form 1116) instead, and others fail to file despite a filing requirement.

Source: IRS SOI Tax Stats Individual Tax Statistics

4. 5,565 expatriations published in calendar year 2024

The Treasury Department publishes a quarterly list of US citizens and long-term residents who chose to expatriate, as required by IRC Section 6039G. Combining the four 2024 quarterly Federal Register lists gives 5,565 names for calendar year 2024.

Annual totals over the last decade range from low hundreds in pre-2010 years to a 2020 record of 6,705. Recent years have averaged 3,000 to 6,000 published expatriations per year. The list captures only those Treasury chose to publish; some expatriations are not published.

Expatriating is not casual. Long-term residents and citizens must file Form 8854; "covered expatriates" face a mark-to-market exit tax on unrealized gains above an exemption threshold ($866,000 for 2024). The decision is irreversible for most US citizens.

Source: Federal Register quarterly publication of expatriation lists

5. Portugal's original NHR regime enrolled over 89,000 residents before closing

Portugal's Non-Habitual Resident (NHR) regime, which offered a 10-year window of favorable foreign-income and pension treatment, granted status to more than 89,000 individuals between its 2009 launch and 2024, when it closed to new applicants. The closure followed political pressure tied to housing affordability in Lisbon and Porto.

A successor regime, IFICI (Incentivo Fiscal à Investigação Científica e Inovação), sometimes called NHR 2.0, replaced NHR for new arrivals from 2024. IFICI is narrower: scientific research, higher-education teaching, qualifying technology and innovation roles, and certain investment activities. Pensions are no longer included. Existing NHR holders retain their grandfathered terms for the remainder of their 10-year window.

NHR remains one of the most consequential expat-tax regimes in Europe by sheer adoption.

Source: Reuters: Portugal to scrap tax breaks for foreign residents

6. Spain's Beckham Law has attracted tens of thousands of inbound applicants

Spain's special expat tax regime, formally Article 93 of the Personal Income Tax Law and informally called the Beckham Law, lets qualifying inbound workers pay a flat 24% rate on Spanish-source employment income up to 600,000 euros for up to six years. Foreign-source income is generally not taxed in Spain under the regime.

Spain's Agencia Tributaria has reported cumulative Beckham Law beneficiary counts in the tens of thousands, with a notable jump after the 2023 reform that opened the regime to digital nomad visa holders, qualifying self-employed professionals, and family members of primary applicants.

The regime is one of the few in Europe explicitly designed to attract high-earning mobile professionals. Election must be filed within six months of arrival.

Source: Spain Agencia Tributaria Beckham Law guidance

7. Italy's impatriate regime tightened sharply in 2024

Italy's Regime Speciale per Lavoratori Impatriati was reformed effective 2024. The pre-2024 version exempted 70% (90% in southern regions) of qualifying employment and self-employment income for five years, extendable. The 2024 reform reduced the exemption to 50% (60% for those moving with a minor child) and capped qualifying income at 600,000 euros.

The Italian Ministry of Economy and Finance's annual Tax Expenditure Reports document the regime's cost in hundreds of millions of euros per year in foregone revenue, implying tens of thousands of beneficiaries cumulatively. The 2024 tightening was driven by that cost growth and concerns the regime was being used by Italians who had briefly worked abroad rather than by inbound talent.

Italy's regime is more restrictive than Spain's Beckham Law because it requires actual employment or qualifying self-employment in Italy, not just residency.

Source: Italy Agenzia delle Entrate impatriate regime guidance

8. The UAE introduced a 90-day tax residency certificate route in 2023

The UAE introduced a new tax residency certificate framework via Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 27 of 2023. A natural person can qualify as a UAE tax resident with 90 days or more of UAE physical presence in a 12-month period, provided they are a UAE national, hold UAE residency, or hold GCC nationality, AND have either a permanent home or carry on employment or business in the UAE.

A simpler 183-day route also exists for any individual regardless of nationality or visa status. The UAE has no personal income tax, so a UAE Tax Residency Certificate (TRC) is primarily useful for treaty access and for proving tax residency to a former home country.

The Federal Tax Authority issues TRCs through its e-services portal. The framework brought UAE rules in line with OECD norms.

Source: UAE Federal Tax Authority Tax Residency Certificate

9. Estonia's e-Residency has issued digital IDs to 137,000+ people, but most are not tax residents

Estonia's e-Residency program had issued digital IDs to more than 137,000 individuals from 170+ countries and seeded 40,000+ companies as of early 2026, per the program's public dashboard. Top applicant countries include Spain, Ukraine, Germany, Russia, and the UK.

Critically, e-Residency is not residency. It is a digital ID that lets non-Estonians establish and run an EU-registered company remotely. The company is an Estonian tax resident; the owner is not, unless they move to Estonia and meet Estonian tax-residency tests (generally 183 days). Many digital nomads conflate the two. Estonia separately runs a dedicated Digital Nomad Visa (launched 2020), but adoption is in the low thousands.

Source: Estonia e-Residency Dashboard

10. UK non-dom population sat near 68,800 before the 2025 reform

HMRC publishes detailed data on the non-domiciled resident (non-dom) population, which numbered around 68,800 individuals claiming non-dom status in 2022-23 per HMRC's own non-dom statistics release. The UK's 2024 Spring Budget announced abolition of the remittance-basis non-dom regime from April 2025, replacing it with a four-year foreign-income-and-gains (FIG) exemption for new arrivals.

The Statutory Residence Test (SRT) is the single test for UK residency. It uses three categories: automatic non-resident (under 16 days, or 46 if not previously resident), automatic resident (183+ days, only home in UK, or full-time UK work), and a "sufficient ties test" combining day count with family, accommodation, work, and 90-day ties.

Source: HMRC Statistics on non-domiciled taxpayers in the UK

11. CRS now exchanges data on 134 million financial accounts annually

The OECD's Common Reporting Standard (CRS) for automatic exchange of financial account information covers more than 100 jurisdictions. The OECD's most recent progress reporting cited automatic exchange of information on around 134 million financial accounts covering approximately 12 trillion euros in assets for the most recent reporting year published.

The United States is not a CRS signatory. It runs the parallel FATCA framework, which requires foreign financial institutions to report US account holders to the IRS. For expats, foreign banks send your account data to your home tax authority regardless of where you reside. This kills the old strategy of being "tax-non-resident anywhere" while still holding a foreign bank account.

Source: OECD Automatic Exchange of Information progress report

12. The "tax-non-resident-anywhere" trap is real and increasingly audited

There is no comprehensive count of nomads claiming no tax residency anywhere, but national tax authorities have made the audit posture clear. HMRC, the ATO, and the CRA have all published guidance warning that leaving your home country does not by itself end tax residency: you must establish residency elsewhere and meet treaty tiebreaker tests if challenged.

The OECD's work on tax challenges of remote work flags the "stateless tax resident" pattern as a compliance concern. Spain's Article 9 LIRPF presumes Spanish residency when the spouse and minor children habitually reside there, regardless of the taxpayer's day count. Portugal applies similar presumptions.

For nomads, "I left and didn't land anywhere" is not a defense. Auditors ask: where do you file? Show us the certificate of tax residency. No certificate, and the country you left often re-asserts residency. This is the most common failure mode for nomads with significant income.

Source: OECD work on tax challenges of digitalisation and remote work

What these numbers tell us

Three patterns emerge. First, the population subject to expat tax-residency rules is genuinely large and growing. Roughly 9 million Americans abroad, 1.5 million FBAR filings, 5,565 published expatriations in 2024, and the large EU regime cohorts (89,000+ Portugal NHR, tens of thousands under Spain's Beckham Law) describe a no-longer-marginal population.

Second, formal compliance lags behavior. The gap between 9 million Americans abroad and roughly 471,000 Form 2555 filers implies many expats use foreign tax credits, fall below filing thresholds, or do not file. FinCEN's Streamlined and Delinquent Submission Procedures continue to attract first-time filers years into their time abroad.

Third, host countries are tightening regimes that previously favored mobile professionals. Portugal closed NHR. Italy halved the impatriate exemption. The UK is abolishing remittance-basis non-dom. The "easy" regimes that powered the 2010s nomad wave are gone or narrower; the new ones (IFICI, post-2024 impatriate, UK FIG) require tighter qualifying activity.

For nomads in 2026, the working assumption should be: someone will claim you as a tax resident, and the only question is which one. Plan for residency rather than against it.

How Nomad helps you navigate this landscape

The statistics above describe a world where day-counts trigger tax consequences in multiple jurisdictions simultaneously. The 6.2-locations-per-year nomad documented in our digital nomad statistics post is the nomad most likely to drift across the 183-day threshold in a country they did not intend to call home.

Nomad (the visa compliance app for digital nomads) automates day-counting against every relevant tax-residency rule. The app tracks days against calendar-year tests (Spain, Portugal, Germany, France, Italy), the UK tax year used by the Statutory Residence Test, rolling 12-month windows, and the multi-year weighted formula of the US Substantial Presence Test. It alerts you 30, 15, and 7 days before any threshold. Passport details stay on your device.

Download Nomad on the App Store

4.8★ - Join 1,000+ digital nomads

Frequently Asked Questions

How many US citizens live abroad in 2026?

The US Department of State estimates approximately 9 million American citizens reside outside the United States. The Federal Voting Assistance Program's most recent Overseas Citizen Population Analysis estimated roughly 4.4 million voting-age civilian US citizens abroad in 2022. No agency precisely counts expats because the US does not require consular registration. The 9 million figure includes private citizens, military, diplomats, and dual nationals.

How many Americans claim the Foreign Earned Income Exclusion?

According to the IRS Statistics of Income, approximately 471,000 individual taxpayers filed Form 2555 for tax year 2021, excluding around $36 billion in foreign earned income. The exclusion cap for 2024 is $126,500 per qualifying individual. Filers must meet either the bona fide residence test or the 330-day physical presence test. The number of FEIE filers has been stable in the 450,000 to 500,000 range for several years.

How many US citizens renounce citizenship each year?

The Treasury Department publishes a quarterly Federal Register list of US citizens and long-term residents who expatriated. Calendar year 2024 totaled 5,565 published names across the four quarterly publications. Annual totals over the last decade have ranged from low hundreds in pre-2010 years to a 2020 record of around 6,705. The list is required by IRC Section 6039G.

What is an FBAR and how many are filed?

An FBAR is the Report of Foreign Bank and Financial Accounts (FinCEN Form 114). Any US person whose aggregate foreign financial accounts exceed $10,000 at any point in a calendar year must file. FinCEN reported approximately 1.5 million FBAR filings in fiscal year 2023. Penalties for willful non-filing reach the greater of $100,000 or 50% of the account balance per violation per year. The FBAR is filed separately from the income tax return.

How many people used Portugal's NHR program?

Portugal's original Non-Habitual Resident regime granted special tax status to more than 89,000 residents between 2009 and its 2024 closure. NHR offered a 10-year window of favorable foreign-income and pension treatment. Portugal replaced it with the narrower IFICI / NHR 2.0 regime, focused on scientific research, higher education, technology, innovation, and certain investment activities. Pensions are no longer included. Existing NHR holders retain their grandfathered terms.

What is the UAE 90-day tax residency rule?

Under UAE Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 27 of 2023, a natural person qualifies as a UAE tax resident with 90+ days of UAE physical presence in a 12-month period, provided they are a UAE national, UAE resident, or GCC national, AND have either a permanent home or carry on employment or business in the UAE. A simpler 183-day route also exists for any individual regardless of nationality.

Can a digital nomad be tax-non-resident anywhere?

Possibly in theory, rarely in practice. National tax authorities increasingly assume continued tax residency in the country you left until you document residency elsewhere. Spain's Article 9 LIRPF presumes Spanish residency in some circumstances even when day-count is under 183. The UK's Statutory Residence Test can keep you resident at as few as 16 days with sufficient ties. Most nomads who believe they are non-resident anywhere actually have an unnoticed residency claim against them.

What is the Common Reporting Standard?

The OECD's Common Reporting Standard (CRS) is the multilateral framework for automatic exchange of financial account information across more than 100 jurisdictions. The most recent OECD progress reporting cited exchange of data on around 134 million financial accounts covering approximately 12 trillion euros in assets. The United States does not participate in CRS; it operates the parallel FATCA framework. Together they mean foreign banks routinely report your account data to your home tax authority.

Where do these tax residency statistics come from?

Primary sources: the IRS Statistics of Income (Form 2555 data), FinCEN's Year in Review (FBAR volume), the US Treasury Federal Register expatriation lists (Section 6039G), the State Department and FVAP (US population abroad), Portugal's tax authority via Reuters (NHR adoption), Spain's Agencia Tributaria (Beckham Law), Italy's Agenzia delle Entrate (impatriate regime), the UAE Federal Tax Authority, Estonia's e-Residency dashboard, HMRC (UK SRT and non-dom data), and the OECD (CRS exchange volumes).

Does the US tax me even if I am a tax resident of another country?

Yes. The United States taxes its citizens and green-card holders on worldwide income regardless of where they live. Triggering tax residency in another country creates a second residency claim. Tax treaty tiebreaker rules and foreign tax credits (Form 1116) or the FEIE (Form 2555) typically prevent literal double taxation, but US filing is not optional. See our US Substantial Presence Test guide and the 183-day rule explainer.

Sources

Every stat links inline. Primary sources used:

Related guides

About Nomad

Nomad is the visa compliance app for digital nomads. Built by nomads for nomads, it tracks your days across every country automatically, alerts you before overstays, and keeps passport details on your device for privacy. The in-app AI assistant answers visa questions in plain English. Available on iOS.

Download Nomad on the App Store →

Important: This content is informational and does not constitute legal, tax, or immigration advice. Visa rules, tax regulations, and entry requirements change frequently and vary by individual circumstances. Always verify current requirements with official government sources or a qualified professional before making travel decisions. Nomad tracks your days and surfaces compliance information, but final responsibility for compliance rests with the traveler.

Download Nomad
★★★★★4.8 - Join 1,000+ digital nomads