The verdict
Hong Kong is the lighter local system. Salaries tax is progressive from 2% to 17% with a standard-rate cap of 15% / 16%, two-tier profits tax is 8.25% / 16.5%, and there is generally no personal capital gains tax, dividend withholding tax, GST or inheritance tax. The United States uses 10% to 37% federal ordinary rates, 21% federal C-corporation tax, 0% to 20% long-term gains and estate tax of up to 40%.
Territorial tax is not a U.S. passport waiver. Hong Kong generally taxes Hong Kong-sourced employment, profits and property income rather than worldwide income. A U.S. citizen who takes a Hong Kong ID still has U.S. worldwide filing and possible U.S. tax, including on income Hong Kong ignores.
Choose Hong Kong for a genuine Asia operating and banking base with source-based tax. Choose the United States for customers, capital and legal infrastructure. Remote founders who never source income in Hong Kong should not expect the salaries-tax table to save them from the IRS.
How to read this comparison
Hong Kong is a source jurisdiction. The United States is a citizenship jurisdiction. That single design difference outweighs most of the rate table for anyone holding a U.S. passport.
Hong Kong does not tax a person's global pile of income. Employment is salaries tax, business is profits tax, and rent is property tax. Salaries tax is progressive from 2% to 17%, with a standard-rate cap of 15% / 16% so the progressive scale does not run away. Two-tier profits tax charges 8.25% on the first HKD 2 million of assessable profits and 16.5% above that, and genuine offshore profits can stay outside profits tax when the source rules are met. There is generally no tax on capital assets sold as capital, no dividend withholding, no GST and no inheritance tax.
The United States starts in a different place. Citizens and resident aliens are generally taxed on worldwide income whether the salary is earned in Central or in Chicago. Federal ordinary rates run from 10% to 37%. Long-term gains and qualified dividends can use 0% to 20%. C corporations pay 21% federally. The federal estate tax can reach 40%. States then add income, sales and property taxes. There is no federal VAT, which is one of the few areas where the United States resembles Hong Kong's consumption-tax gap.
A U.S. citizen who relocates to Hong Kong can therefore collect a light local assessment and a full IRS year at the same time. Foreign tax credits may absorb some U.S. tax on Hong Kong-source salary. They do not automatically shelter foreign-source investment income that Hong Kong never taxed. FBAR, Form 8938 and CFC-style reporting still apply. Hong Kong territoriality is not a substitute for expatriation.
Substance and source still have to be real. A company that books invoices through Hong Kong while management sits in California is arguing with both the Inland Revenue Department and the IRS. Stamp duty on property and stock transfers can also surprise people who heard โno GST.โ Use Hong Kong when the work, contracts and profits arise there. Use the United States when the commercial centre is American. If you keep U.S. citizenship, model both answers on the same income.