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In recent months, the global mobility landscape has undergone significant changes due to several key developments. These include the passage of the US One Big Beautiful Bill Act (OBBBA) (H.R. 1) on July 4, the flurry of tariff activity since April, increased US immigration scrutiny and ongoing international mobility trends. Together these factors have created a complex and fast-evolving environment for multinational companies managing global assignments.

So, what does this mean for inbound and outbound US assignments? Will we continue to see the shift toward shorter US outbound assignments? Will inbound mobility to the US gain even greater momentum? And how will best practices adapt in the face of these new challenges?

In this insight, Vistra’s Head of Global People Advisory, Saul Howerton and Paul Rubino, Senior Director of US Expatriate Tax, explore where we’ve been, what’s changed and where global mobility may be headed next.

 

Pre-2025 US global mobility trends

In the lead up to 2025, US multinationals were already rethinking assignment strategy, notably moving toward shorter US outbound tax-equalised assignments. This trend was driven by several factors:

  • US tax rates were already lower than many foreign countries (especially in Europe) making ‘gross-up’ payments expensive.
  • Rising global inflation increased the cost of assignment benefits like the Cost of Living Allowance (COLA) and housing allowances.
  • Numerous companies accelerated the transition to local personnel to minimize costs and reduce ramp-up time.

At the same time, US inbound assignments were becoming more appealing from a cost perspective. Some companies used inbound assignments to offset outbound costs, especially through tax equalisation programs favouring US-based mobility.

 

The OBBBA and impacts on global mobility

Before considering the impact of tariffs, let’s review the key changes in the OBBBA from a US global mobility perspective. The new tax law didn’t make radical changes for inbound or outbound US expats. Instead, the Act preserved most of the previous tax legislation that was set to expire after 2025. This continuity provides valued certainty to the business world in a time of change, volatility and ambiguity.

However, there are a number of tax changes under the new law that might affect some expats. These include changes to overtime pay rules, the state and local tax (SALT) cap, electric vehicle and child tax credits, qualified small business stock (QSBS) and alternative minimum tax (AMT) among other provisions. While the hypothetical home-country baseline taxes for both outbound and inbound tax-equalised assignments are generally expected to result in lower overall US tax liability after the OBBBA, in most cases the difference from pre-Act levels will not be significant.

The Act also includes corporate tax incentives that encourage businesses to produce and invest more within the United States. Because of these incentives, the current trends in US global mobility are expected to continue. 

 

Tariff impacts on global mobility: the x factor

Now let’s add tariffs to the global mobility equation. This will likely be the X factor to consider. The main goal of the US tariff policies is to lower the costs/obstacles for exporting US goods abroad while onshoring investments into the US for job and wage growth. If both can be accomplished, that’s a win-win for US companies from both an inbound and outbound global mobility perspective. 

Inbound mobility to the US is expected to benefit the most. Lower US tax rates for expats compared to their home countries might encourage companies to bring more talent to the US to open up new or existing markets. The one major speed bump could be US immigration policies and how open the US will be to foreign talent. In September 2025, we saw the administration raise the cost of the all-important H-1B visa - which allows US employers to temporarily employ foreign workers in speciality occupations - to 100,000 USD.

Still, if the immigration variable can be resolved favourably, then we would expect to see strong growth in inbound mobility. 

US outbound mobility could also see some upside for a multinational’s expansion plans under this new global framework. Easing tariffs on US goods and foreign import obstacles would likely bring about new US company expansion opportunities overseas, increasing the demand for US expats. Tax and other cost factors for these expats will still play a significant role as to duration, cost-plus benefits package, tax equalisation, treaty application, equity planning and corporate-level considerations. 

Tariffs are still in a major state of flux, but the upside should be there for US global mobility if these trade deals are successfully implemented.

 

Where are we headed? Follow the investment

Tariffs, taxes, and immigration have undeniably reshaped the global mobility playbook, but where is this all going?

If planned US investments materialise, there will be heightened demand for skilled talent on American soil. Add in the widening tax gap between the US and higher-tax jurisdictions, and the US could become an attractive destination for global mobility programs.

At the same time, longer-term US outbound assignments are declining. Instead, companies are choosing either: 

a) Short-term tax-equalized assignments of 6 to 18 months, or
b) Permanent transfers where employees are transitioned more quickly to local pay and benefits (early localisation)

 

Key considerations for US inbound vs. outbound mobility

US inbound strategy

  • Gain an understanding of the US immigration landscape and get local legal support.
  • Consider tax equalisation rather than straight permanent transfer unless tax savings to the expat are part of the package to remain competitive in your market/industry.
  • If tax equalisation isn’t used, consider reducing tax protections on US assignment benefits. Consider state locations, remote work and business travel criteria to maximise tax savings to the expat and company.

US outbound strategy

  • Consider initial assignment durations of 6, 12 or 18 months to benefit from special tax rules.
  • Plan for expat localisation earlier by setting expectations and considering industry or market standards to stay competitive.
  • Ensure tax equalisation programs are truly global, especially where tax benefits can be reclaimed when sending talent to lower tax jurisdictions (e.g. HK/SG).

Overall recommendations

  • For existing assignments, review for hypothetical taxes (if tax equalised) and tax accruals for assignment cost sustainability.
  • For planned assignments update tax cost estimates and whether assignment parameters and packages should be modified in light of the above changes.
  • Review how the OBBBA's new tax law affects your global mobility costs and policies.
  • Model and benchmark potential tax costs to understand their impact on your global workforce mobility.
  • Evaluate the comp/benefits/equity packages and HR/tax equalisation policies to ensure OBBBA compliance and competitiveness in local markets.

Early-stage planning is key. Partnering with experts who understand global taxmobility and compliance is critical to navigating this complex and changing environment.

At Vistra, our International Expansion teams are here to help. With over 10,000 experts across 170+ countries, we’re ready to guide your mobility strategy—wherever it takes you.

Contact a member of the Vistra team today to learn how we can support your global mobility strategy.

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About the authors
Saul Howerton is Vice President and Global Head of People Advisory at Vistra. With over 20 years of experience in consulting, operations, and finance, he specializes in HR, global mobility, and back-office outsourcing. He helps high-growth companies streamline operations, structure entities, and expand internationally to drive sustainable growth.

Paul Rubino is Senior Director of Vistra’s US Expatriate Tax Services practice, where he supports companies expanding internationally with tailored US tax solutions. Drawing on deep experience from Big Four firms and global mobility leadership roles, he helps organizations manage tax compliance efficiently while enabling successful cross-border growth.

Contacts

Saul Howerton
Saul Howerton
Vice President, Advisory
Paul Rubino
Paul Rubino
Senior Director, US Expatriate Tax Services