Sell first, then move, or move first, then sell? For a Canadian founder with a CAD 2M business, that order-of-operations decision is worth roughly CAD 300,000. Most people never model it.

Wrong answer costs six or seven figures for many founders. Right answer captures both benefits.

The Three Sequences

Sequence A: Sell first, then emigrate. You sell the business as an Australian, Canadian, UK, or US resident. Full home-country tax rules apply to the sale. Then you emigrate with cash.

• Benefits: access to home-country reliefs (Australian small business concessions, UK Business Asset Disposal Relief, Canadian QSBC and LCGE, US Section 1202 QSBS); simpler mechanics; a clean emigration as a cash holder, since you no longer own business shares for departure tax to bite on

• Best for: founders whose home country offers substantial small business CGT concessions, and founders who don't need the tax deferral a post-departure sale would buy them

Sequence B: Emigrate first, then sell. You emigrate. A departure event on business shares (deemed disposal) applies if relevant — or you elect deferral where that's available. Then you sell the business post-emigration.

• Benefits: post-departure appreciation escapes home-country tax; your new residence country's rules apply to future growth; deferral of home-country departure tax is possible via security in some jurisdictions

• Best for: founders whose business has substantial expected growth still ahead of it, founders whose destination country has more favourable CGT treatment, and founders in home countries with less generous small business reliefs

Sequence C: Restructure first, then emigrate, then sell. Pre-emigration structural reorganisation, then emigration, then a sale from the restructured entity.

• Benefits: can achieve tax outcomes not available under Sequence A or B alone; may enable better buyer structuring; can incorporate succession planning at the same time

• Best for: HNW founders with more complex situations (multiple businesses, family considerations), founders with buyer types that prefer certain structures, and founders with 24+ months before their intended events

The Country-Specific Math

• Australian, small business CGT concession eligible
  Business value: AUD 3M active business
  Sequence A (sell first): CGT can be eliminated entirely, within the net-asset and turnover eligibility tests
  Sequence B (emigrate first): CGT Event I1 at 47% marginal × 50% discount = 23.5% on the gain, roughly AUD 700K tax
  Winner: Sequence A

• Canadian, QSBC-qualifying
  Business value: CAD 2M business
  Sequence A (sell first): LCGE shelters roughly CAD 1.25M; balance taxed at capital gains rates; total tax roughly CAD 200K
  Sequence B (emigrate first): Section 128.1 crystallises the gain at roughly 26.75% effective rate, roughly CAD 500K tax, with no LCGE available on departure
  Winner: Sequence A

• US, QSBS-qualifying
  Business value: USD 5M SaaS business
  Sequence A (sell first): Section 1202 can exempt up to USD 10M of gain for stock acquired on or before 4 July 2025, or up to USD 15M for stock acquired after that date under the OBBBA (subject to a tiered holding period), plus state tax if applicable
  Sequence B (emigrate first): Same US federal outcome as Sequence A, since citizenship-based taxation follows you regardless — but state tax elimination is added
  Winner: Sequence A plus state tax planning (renunciation is a separate, larger decision — see Leaving the US as an Online Business Owner, A11)

• UK, BADR-eligible
  Business value: GBP 4M business
  Sequence A (sell first): Business Asset Disposal Relief cuts CGT to 18% (from 6 April 2026) on the first GBP 1M of qualifying gain, then 24% on the balance
  Sequence B (emigrate first): No UK exit tax — UK CGT doesn't crystallise on emigration. But if you become non-resident and sell within 5 years, temporary non-residence rules pull the gain back
  Winner: Sequence A, generally, unless you're genuinely emigrating for 5+ years

When Sequence C (Restructure First) Fits

Worth considering when:

• Small business reliefs don't apply to your specific business

• A buyer type prefers a foreign-domiciled acquisition target

• Family succession considerations sit alongside the sale

• Multiple businesses need separate treatment

• You have 24+ months before your intended events

Rarely worth it for:

• Solo founders with a single, simple business

• Situations where home-country reliefs are already generous

• Time-pressured sales

The Practical Framework

• What home-country CGT reliefs apply to my business? (LCGE/QSBC for Canadians, BADR for UK founders, small business concessions for Australians, QSBS for US founders.)

• How much value will the business gain between now and an eventual sale?

• What are the buyer's structural preferences?

• How long can I wait before either event?

• Does my chosen destination country have CGT rules that affect a post-departure sale?

Answer those five, and the sequence typically becomes obvious.

The Common Trap

Choosing a sequence based on "which country will tax me less," without weighing home-country reliefs at all. For most home countries, the small business CGT reliefs are generous enough that using them before departure beats every other option on the table. The mistake is emigrating first and giving those reliefs up for nothing.

Model the Sequence Before You Do Either

If you're within 24 months of both a sale and a move, book a scoping call. We'll run the actual sequence math for your country, your business value, and your relief eligibility — this is one of the highest-value planning windows a founder gets, and it's easy to get the order wrong without modelling it first.

Related: Leaving the US as an Online Business Owner (A11); Leaving Australia as an Online Business Owner (A14); Where Should Your Online Business Be Incorporated? (A1); Exit Planning for Online Business Owners (A28).

General information, not personal tax or legal advice. Sale-plus-emigration planning is highly fact-specific, and relief rates shift — both the UK and US figures in this piece changed in 2026. Confirm current numbers with a qualified adviser before acting.