Dependency Geometry

Definition

Dependency geometry is the structural analysis of how a family’s citizenship, residency, tax obligations, and asset positions create interdependencies across jurisdictions. It maps not just where exposure exists, but how decisions in one jurisdiction cascade through obligations in others.

The Problem It Solves

Most families approaching international planning treat each decision independently: the citizenship question goes to an immigration lawyer, the tax question goes to a CPA, the asset protection question goes to an estate attorney, and the residency question goes to a relocation consultant. Each advisor optimises within their domain. None sees the interaction effects between domains.

Dependency geometry makes those interaction effects visible. It reveals, for example, that establishing tax residency in Italy before restructuring U.S. holdings can trigger a covered expatriate determination under IRC 877A — not because of anything Italy did, but because the sequence of the residency decision and the restructuring decision interact with U.S. exit tax provisions in ways that neither the Italian tax advisor nor the U.S. immigration attorney would independently flag.

The Model

A family’s jurisdictional footprint can be mapped across four primary dimensions: nationality (where they hold citizenship), residency (where they have legal or tax residence), assets (where their wealth is held and structured), and obligations (where governments claim authority over their income, estate, or person). Each position in each dimension creates dependencies — some visible, some latent.

The “geometry” is the shape of these dependencies in aggregate. A family with a single citizenship, single tax residency, and assets concentrated in one jurisdiction has a point — total concentration, maximum dependency. A family with two citizenships, a tax residency in a third jurisdiction, and assets distributed across a fourth and fifth has a polygon — diversified, with no single point of failure.

The goal of sovereign planning is not maximum complexity. It is the minimum viable geometry that eliminates single points of failure while remaining operationally manageable and legally compliant across all relevant jurisdictions.

Common Failure Patterns

The most frequent failure patterns we observe are not exotic. They are structural: a family with U.S. citizenship as their only nationality, all assets in U.S. institutions, and a plan to “just move to Portugal” without accounting for the fact that the U.S. will continue to tax their worldwide income regardless of where they live. The geometry here is a line — two points, one dependency. Moving does not diversify; it adds a point without reducing the primary exposure.

True diversification requires changing the geometry itself: adding a nationality that is not conditioned on residence, establishing asset positions in jurisdictions not subject to the same legal system, and structuring tax residency in a way that accounts for treaty interactions across all relevant jurisdictions simultaneously.