EU residence for American and Canadian founders and investors

More American and Canadian founders and investors are looking at Europe as a place to live, build a company or hold assets. The EU has no single residence permit for them: each country runs its own routes, and they change. This guide explains the main types of route, what has closed, and the home-country tax points that often get missed. It is general information, not advice on which route you personally should use.

Visa-free travel has limits

US and Canadian citizens can visit the Schengen area without a visa for short stays. The Government of Canada’s travel advice explains that visa-free travel only applies to stays of up to 90 days in any 180-day period, and that stays are cumulative across all Schengen countries.

Two border changes matter for frequent visitors. According to the European Commission, the Entry/Exit System has been fully operational since 10 April 2026, recording non-EU travellers’ entries, exits and biometric data at the border. The Commission also says US citizens will need an ETIAS travel authorisation for short stays once the system starts. At the time of writing (October 2026), ETIAS is scheduled for the last quarter of 2026, with the exact date to be announced. Canada’s travel advice says the same applies to Canadians.

Ninety days is enough for meetings and setting up a company. It is not residence. To live in an EU country, you need a national visa or residence permit from that country.

Founder routes: startup visas

Several EU countries run startup visa programmes for founders from outside the EU. Two examples:

Lithuania. The Startup Visa programme, powered by Startup Lithuania, assesses innovative non-EU founders through an online application, a pitch deck, a 30-minute video interview for shortlisted applicants and an expert committee. A successful applicant receives a confirmation letter that supports an application for a visa and temporary residence permit. The permit is valid for two years, with a possibility to extend it to five, and family members can apply too. The final decision rests with Lithuania’s Migration Department.

Estonia. Startup Estonia’s startup visa is for companies that meet the startup definition in Estonia’s Aliens Act: innovative, scalable, with global growth potential, and no older than 10 years. A long-stay startup visa lasts up to 365 days and can be extended for another 183 days. Family members can be granted the same visa.

Startup visas reward innovation and growth potential, not simply money. If your business is a consultancy, a holding company or a traditional trade, look at business routes instead.

Business and investment routes

Some countries issue residence permits to people who invest in and run a local business:

• Estonia. Startup Estonia explains that you can apply for a residence permit for business if you hold a stake in a company and have invested at least €65,000 of capital in business activity in Estonia, or €16,000 as a self-employed person.
• Lithuania. The EU Immigration Portal describes permits for people whose share in a Lithuanian company is at least €14,000, where the company employs Lithuanian, EU or EFTA citizens or permanent residents and meets other conditions in national law. It also mentions investors who take part directly in projects of importance to the state. Family members of people in these groups can apply for residence immediately, without the usual two-year wait.

These routes are built around a real, operating business. Check the detailed conditions with the authority concerned before you commit any money.

What has closed

Investor routes in Europe have narrowed. Ireland’s Immigrant Investor Programme, which offered residence in return for large investments or endowments, closed to new applications on 15 February 2023, according to the Irish Department of Justice. The same announcement confirmed that Ireland’s Start-up Entrepreneur Programme for innovative founders would continue.

Be cautious of anyone selling “guaranteed” EU residence for an investment. Check any scheme directly with the government that runs it.

Your home tax obligations

Moving to Europe does not end your tax ties at home, and this is where many people get caught out.

United States. The IRS states that US citizens and resident aliens are taxed on worldwide income, wherever they live. Many Americans abroad can use the foreign earned income exclusion or the foreign tax credit, but only by filing a US return. US taxpayers with foreign financial accounts above the reporting threshold must also report them on an FBAR, even if the accounts produce no taxable income.

Canada. The Canada Revenue Agency explains that you generally become an emigrant for tax purposes when you leave Canada to live abroad and sever your residential ties. If you keep significant ties, such as a home or family in Canada, you may remain a factual resident. When you emigrate, you are generally treated as having sold certain property at its fair market value, which can create a capital gain, and you must file Form T1161 if the property you own is worth more than $25,000.

Your new country will have its own rules on when you become tax resident. Get advice from qualified tax advisers on both sides before you move.

Planning the move

A few principles help:

• Start with the business, not the permit. Choose the country that suits your company and life, then the route.
• Plan for family. Check who can come with you, when, and whether your partner can work.
• Allow time. Assessments, permits and bank accounts all take time.
• Use official channels. Apply through government portals and embassies, and use regulated lawyers or advisers.

No one can guarantee a residence permit. Decisions are made by the authorities alone.

How Mavericks Settle helps

Mavericks Settle guides founders, investors and families through moving: the right residency route for you, paperwork and applications, bank accounts, finding a home and settling in, with legal steps handled by our regulated partner law firms. For investors looking at European companies, Mavericks Connect makes introductions to counterparts and opportunities, by introduction only.