UK, U.S. or Canada?
The three systems differ a lot. This table uses the public rules on the date checked to give you the general picture; your own case needs an assessment.
Information checked: 5 November 2026 · UK rules change often; check GOV.UK before you apply
| United Kingdom | United States | Canada | |
|---|---|---|---|
| Main work visa | Skilled Worker (licensed sponsor, degree-level job, usually ≥ £41,700) | H-1B (annual lottery), L-1 (intracompany), O-1 (extraordinary ability) | Employer permits (often LMIA), intra-company transfer, post-graduation permit |
| Permanent status | Indefinite Leave to Remain (ILR) | Green card (lawful permanent resident) | Permanent resident (PR) |
| Time to permanent status | New model: 10 years by default; 3–5 years for high earners or certain jobs; family of British citizens and BN(O) keep current paths | Depends on category and country of birth; mainland China-born employment applicants usually wait for a visa number | Express Entry and other programs lead straight to PR; IRCC targets about 6 months after an invitation |
| Talent routes without an employer | Global Talent, High Potential Individual | EB-1A, EB-2 NIW (self-petition) | Express Entry (points-based draws) |
| Investment or business | No investor visa (Tier 1 Investor closed 2022); Innovator Founder visa | EB-5 ($800,000 in a TEA, $1,050,000 elsewhere); E-2 for treaty nationals | Mainly start-up and provincial entrepreneur streams, which change often; IRCC prevails |
| Citizenship | Usually 12 months after ILR, with 5 years' residence (3 for spouses of British citizens) | 5 years after the green card (3 for spouses of U.S. citizens) | 1,095 days of physical presence in the 5 years before applying, as a PR |
| Dual nationality | Allowed | Allowed | Allowed |
Note: Chinese law does not recognise dual nationality. Rules change often; this table is an overview, not legal advice.
Who each country tends to suit
The best route depends on your background:
The UK may suit
Graduates of UK universities or people who can land a well-paid UK job; Hong Kong BN(O) families; partners of British citizens.
The U.S. may suit
Investors who can fund EB-5 or run an E-2 business (E-2 needs treaty nationality); people with a strong record for NIW or EB-1A; people with a U.S. employer.
Canada may suit
Younger applicants with degrees and language scores who score well in Express Entry; French speakers.
Not sure which route fits?
Tell us about your situation. We will introduce a partner UK solicitor to speak with you directly, and our U.S. attorney handles anything involving the United States.