What makes the American DNV decision different
Citizenship-based taxation
The US (along with Eritrea and the Philippines for non-residents) taxes its citizens on worldwide income regardless of residence. Moving to Portugal doesn't make your foreign income exempt from US tax. The Foreign Earned Income Exclusion (FEIE, €126,500 for 2025) and Foreign Tax Credit help, but you remain in the US tax system permanently as a US citizen.
This means "zero local tax" Croatian or Icelandic structures don't translate to zero global tax for Americans — you still owe US tax on income above the FEIE threshold.
FATCA reporting
Americans with foreign bank accounts above €10,000 aggregate balance must file FBAR. Above €200,000 (single) or €400,000 (joint) on the last day of the year, Form 8938 applies. Foreign banking gets more complex; some European banks decline US clients due to FATCA compliance overhead.
Social security totalisation
The US has bilateral totalisation agreements with most EU countries (Spain, Portugal, Italy, Greece, Netherlands, Germany, etc.) but NOT all. An A1-equivalent Certificate of Coverage lets you stay on US Social Security and avoid double-payment of local social charges. Hungary's 2024 treaty termination broke this for Hungary specifically.
LLC pass-through interaction
US LLCs are treated as disregarded entities (single-member) or partnerships (multi-member) for US tax — income passes through to the owner. European tax authorities don't always recognise this pass-through treatment, sometimes treating the LLC as a foreign corporation. The interaction is country-specific; Croatia, Romania, and Cyprus tend to be the most LLC-friendly. Spain and Italy are the trickiest.