04 April 2025 · Country Matchups · Global
USA vs Australia: Investor Visa Opportunities
An evidence-based showdown for globally minded capital
Why These Two?
For the globally mobile high-net-worth individual (HNWI), the U.S. and Australia routinely top the “where should I plant a second flag?” short-list. The appeal is obvious:
- Resilient, English-speaking economies
- Predictable (albeit complex) legal systems
- Ivy-league-level universities and enviable lifestyle perks
- A path—however serpentine—to eventual citizenship
But the devil, as ever, is in the programme detail. I spend my days modelling wealth-migration scenarios for founders, fund managers and family offices. What follows is the side-by-side comparison I wish more clients read before they asked me to “just set up an LLC and see what happens.”
1. EB-5 vs Business Innovation Streams: The Elevator Pitches
EB-5 (United States)
Think of EB-5 as a job-creation deal: invest into a qualified enterprise, prove ten American jobs were indirectly spawned, and collect a U.S. Green Card for you, your spouse and kids under 21. There are two flavours:
- Direct EB-5: hands-on management, full job-counting responsibility.
- Regional Center EB-5: pool capital with other investors via an approved fund; looser day-to-day involvement.
The latter captures ~95 % of uptake because busy investors prefer escrowed funds in an existing project to running a craft-brewery in Iowa.
Business Innovation & Investment Program (BIIP, Australia)
Australia’s BIIP is a buffet of four streams, but two take most of the airtime:
- 188A – Business Innovation: buy or establish an operating business; demonstrate AUD 750 k turnover; personal assets of AUD 1.25 m.
- 188B – Investor: invest AUD 2.5 m in a State-endorsed managed-fund portfolio (think bonds, PE, VC, small-cap equities).
Both are provisional visas valid for five years, convertible to the 888 permanent residence (PR) subclass after meeting thresholds on physical presence and economic contribution. There’s also 188C (Significant Investor, AUD 5 m) and 188E (Entrepreneur, AUD 200 k), but we’ll keep our focus on the mainstream 188A/B where most Boardroom discussions happen.
Investor sound-bite:
“EB-5 sells you a Green Card; BIIP sells you options—and a compulsory trip to Costco for sunblock.”
2. Minimum Capital & Associated Costs
| Programme | Statutory Minimum | Real-World “All-in” Cost* | Capital Lock-up |
|---|---|---|---|
| EB-5 Regional Center | USD 800 k (Targeted Employment Area) or USD 1.05 m | USD 920 k–1.2 m (legal, admin fees, regional centre carry) | 5–7 yrs typical |
| 188A | AUD 200 k to buy/launch a business + AUD 1.25 m net assets | AUD 400 k–600 k (purchase price, due-diligence, relocation) | Indefinite if you keep business |
| 188B | AUD 2.5 m into complying investments | AUD 2.6 m–2.8 m (plus mgmt fees) | 4 yrs min |
*Excludes family relocation and advisory fees.
Key takeaways:
-
Sticker Shock vs Liquidity
EB-5 looks cheaper upfront than 188B, but funds are tied in a single project with opaque exit horizons. 188B imposes a heftier cheque yet offers a genuinely diversified portfolio (at least 20 % venture/private equity). -
Currency Exposure
USD and AUD move in opposite cycles to EUR or GBP portfolios. Hedging costs should appear in your model—ignore at your peril. -
Ancillary Spend
Expect USD 10–15 k in U.S. immigration attorney fees; Australia runs closer to AUD 12–20 k. Both jurisdictions pile on government filing fees (USD 3 9 0 0 EB-5, AUD 9 4 5 0 188A/B primary applicant).
3. Timelines: From Wire Transfer to Permanent Status
United States
- I-526E petition filed ⇒ 24–36 months adjudication (yes, really).
- Conditional Green Card (2 yrs) issued once visa number is current.
- File I-829 to remove conditions at year 2 ⇒ another 24 months typical.
- Total: 4–6 years to “unconditional” Permanent Residence.
Fast-track? Only nationals from countries with low EB-5 demand can skip the State-side queue via concurrent filing, but processing still drags.
Australia
- EOI (Expression of Interest) + State nomination ⇒ 2–8 weeks.
- 188 visa lodged ⇒ 8–15 months processing.
- Live in Australia on 188 (5 yrs validity).
- Convert to 888 PR after holding investment for 4 yrs AND residing 2 yrs cumulative.
- Total: ~5 years typical, though immediate work & study rights start on landing.
Observation: Australia is faster to enter, but still demands a multi-year performance test before PR—much like a venture partner wanting to see you sweat first.
4. Managerial & Job-Creation Obligations
EB-5’s ten-job requirement is binary: no jobs, no Green Card. If the regional centre floods, merges or under-delivers, investors face redeployment or their petition is torpedoed. Due diligence on project fundamentals (leasing, cap-rate, developer track record) is non-negotiable.
BIIP 188A bigger headache: you must actively manage the business, maintain turnover thresholds, employ locals, and log your personal presence in-country. 188B is simpler: meet the “complying investment” allocation (20 % VC/PE; 30 % small-cap; rest in balanced funds) and keep the statements for audit.
Pro-tip:
BorderPilot’s data feed scrapes ASIC and U.S. SEC filings weekly. Flagged changes in a fund’s prospectus trigger early alerts in your personalised relocation dashboard—small edge, large sleep quality.
5. Path to Citizenship: Eyes on the Passport
| Requirement | United States | Australia |
|---|---|---|
| Minimum PR years before naturalisation | 5 yrs (3 yrs if married to a U.S. citizen) | 4 yrs residence, incl. 1 yr as PR |
| Physical presence test | 30 months in U.S. over 5 yrs | 3 yrs inside AUS over 4 yrs; no >12 mo away |
| English / Civics | Civics & language interview | Basic English + citizenship test |
| Dual nationality tolerance | Permitted | Permitted since 2002 |
| Military / oath | Oath of Allegiance (pledging to bear arms if required) | Pledge of Commitment, no military clause |
Practical insight: Australia grants a Certificate of Citizenship within weeks of passing the test—a PDF your accountant can laminate if that’s your thing. The U.S. can take 3–6 months between N-400 filing and Oath, with travel limitations while pending.
6. The Tax Residency Traps Most Pitch Decks Skip
United States: The Worldwide-Tax Stick
Once you own a Green Card—or clock 183 days under the substantial presence formula—you’re a U.S. tax resident. That means:
- Global income exposed to federal tax (up to 37 %), plus state tax if you domicile in e.g. California.
- Estate tax at death on worldwide assets (> USD 12.92 m) at 40 %.
- Reporting duties: FBAR, Form 8938, GILTI if you run controlled foreign corps.
If this acronyms stew gives you heartburn, revisit renunciation costs. More than one EB-5 alumnus has traded the Green Card for a Spanish NIE to avoid punitive taxation—documented in our Tracking days in Schengen – apps and best practices article.
Australia: Residence by “Ordinary Concepts” (Translation: It’s Murky)
Australia taxes residents on worldwide income at a top personal rate of 45 % over AUD 180 k. You’re “resident” if:
- Your primary home (‘domicile’) is in Australia unless a permanent place of abode exists abroad; or
- You spend ≥183 days there; or
- You migrate to Australia with intention to reside.
Two practical quirks:
- Capital Gains Discount: 50 % on assets held >12 months, better than U.S. long-term rate for many brackets.
- No Estate Tax: Australia scrapped inheritance tax in 1979 (cue high-net-worth fist-bump).
Structuring Solutions
- Pre-immigration trusts (overseas, irrevocable)
- Dual-corporate holding: U.S. C-corp + Australian discretionary trust
- Asset realisation/step-up before triggering residency
These are chess, not checkers. Use the window after visa grant but before residency clock starts to restructure. Our algorithm suggests ideal relocation “landing dates” by modelling the intersection of visa validity and tax year boundaries—yes, the Australian tax year ends 30 June, not 31 December.
7. Secondary Variables: Lifestyle, Education, Exit Options
Because decision-making isn’t a spreadsheet alone.
| Factor | United States | Australia |
|---|---|---|
| School fees (private K-12) | USD 15–45 k p.a. | AUD 20–40 k p.a. |
| University for PR holders | Domestic tuition rates (e.g. ~USD 15 k UCLA) | Commonwealth-supported places: AUD 8–14 k |
| Healthcare | Private insurance ~USD 7 k family; Medicare if citizen | Medicare benefits for PR; private ~AUD 5 k |
| Safety ranking (Numbeo) | 56/147 cities | 12/147 |
| Flight time to Asia HQ | 14 h NYC→HKG | 8 h SYD→HKG |
Add climate desirability, political polarity, proximity to family offices—you’ll get different weights. My Singapore-based tech founders usually lean Australia for time-zone friendliness; Latin-American families chasing Ivy League pivot to EB-5.
8. Case Study Snapshots
Case 1: SaaS Founder, 34, Latin America
- Liquid proceeds: USD 1.1 m.
- Goal: Access to U.S. venture scene, eventual IPO.
- Outcome: EB-5 regional centre in Texas TEA; relocates to Austin. Accepts worldwide tax, offsets with QSBS planning. Invests family trust into Delaware C-Corp pre-Green Card.
Case 2: Family Office Principal, 55, Hong Kong
- Deployable capital: USD 5 m.
- Goal: Kid’s education, geopolitical hedge.
- Outcome: 188B Investor visa; AUD 2.5 m across State-endorsed funds (25 % VC). Spends 120 days/year in Sydney, preserves Asian domicile for tax. Considers 188C upgrade for larger asset play.
Case 3: Serial Entrepreneur, 42, EU-27 Citizen
- Capital: EUR 600 k, but high cash-flow business.
- Goal: Anglophone market, surfing weekends.
- Outcome: 188A Business Innovation. Purchases Gold Coast digital-marketing agency. Uses our workflow engine—similar to the one we deployed for the Netherlands Start-up Visa milestones for renewal—to track turnover targets and staff headcount.
9. Decision Matrix: Which Route Fits You?
| Priority | Choose EB-5 if… | Choose 188A/B if… |
|---|---|---|
| Capital efficiency | You have USD 800 k but not AUD 2.5 m | You can spare AUD 2.5 m / want business control |
| Speed to work in country | Willing to play 24-month waiting game | Need immediate onshore presence |
| Tax minimisation | Comfortable with U.S. worldwide tax, or planning to expatriate later | Value estate-tax freedom & easier non-dom status |
| Children’s education | Eyeing Ivy League or NCAA dreams | Prefer UK-style schooling, Asian proximity |
| Hands-off involvement | Prefer passive fund investment | Happy to manage, or relocate senior staff |
| Visa quota risk | Country of chargeability has low EB-5 backlog | No restrictive annual cap—Australia rarely backlogs BIIP |
If you tick more boxes on one column than the other, there’s your leaning. Grey zone? Hybrid plan—park capital in Australian fund, apply for EB-5 concurrently, decide which sticks first. I’ve orchestrated that dance more than once.
10. Practical Next Steps
- Run the Numbers: Model after-tax IRR under both regimes for 10-year horizon. Our platform crunches 30 years of FX data and 6,000 syndicated fund returns—worth the 90-second form fill.
- Pre-Immigration Tax Audit: Engage counsel before I-526 or 188 lodgement. The “flag date” is when residency triggers, not fund wiring day.
- Project Due Diligence: Validate regional centre job-creation methodology or Australian fund’s historic compliance.
- Time-Tracking Stack: Repurpose the Schengen-bound apps in our earlier guide to monitor U.S. and AU physical days—simple, interoperable with your phone’s health data.
- Relocation Playbook: School enrolment, Medicare registration, driver’s licence swap; we auto-generate a 37-item checklist tailored to your family profile.
“Global mobility is capital allocation by another name. Deploy both with the same rigour.”
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