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May 5, 2016 - Phil Hodgen

That quarterly published of expatriates – an anecdote

The U.S. government publishes a quarterly list of expatriates (by name), presumably for reasons derived from this country’s Puritan roots.  (I kid, I kid!)  

People often wonder if the list is complete.  Well, who knows.  We can all doff our tin-foil hats for a moment and debate whether the list is selectively curated by the bureaucrats who have the job.

What is undeniable, however, is that there is delay.

A report from the field, from someone I know (published with permission):

As a point of interest, as I am sure you know there are many blogs, etc on the net about just who gets published (quarterly) by the Gov after they expatriate.

... continue reading
Expatriation
April 26, 2016 - Phil Hodgen

IRA Distributions for Noncovered Expatriates

Hello from Phil again, and welcome to this edition of the Expatration Only newsletter.

If you want to stop getting this newsletter (it comes every other Tuesday at 6 am Pacific Standard/Daylight Time), click the Unsubscribe button at the bottom of this newsletter.

IRA Distributions to Noncovered Expatriates

Many people have Individual Retirement Accounts when they expatriate. This time, I will talk about how to handle IRA distributions after expatriation – for noncovered expatriates. The prompt came from reader LC, who emailed me a question. Lightly edited (to hide personally-identifiable facts), this is what LC sent me:

I currently live in [country with no income tax and no income tax treaty with the USA].

... continue reading
Expatriation
April 12, 2016 - Phil Hodgen

Green Card Holders Abroad, Gifts, and Gotchas

Hi and welcome again from Phil. This is the every-other-Tuesday Expatriation newsletter. You can stop getting it by clicking the unsubscribe link at the bottom of this email.

Green Card Holders Abroad, Gifts, and Gotchas

James Simango emailed me to follow up on the email I did about gifts by green card holders domiciled outside the United States. (Spoiler alert: they aren’t taxable “gifts” and this makes possible all sorts of pre-expatriation tax planning). He mentioned Section 1041 and specifically the situation of gifts to noncitizen spouses mentioned in Section 1041(d).

James is right. Just because a transfer is not subject to gift tax does not mean you are out of the woods.... continue reading

Expatriation
March 29, 2016 - Phil Hodgen

Green Card Holders, No Gift Tax, and Expatriation

Hello again from Phil Hodgen. You signed up for the every-other-Tuesday newsletter about expatriation topics, and (surprise, surprise, surprise) here it is. (You get bonus points for knowing the ’60s TV reference). If you want to stop getting these emails, just click the Unsubscribe link at the bottom of the email.

Green Card Holders Abroad and Gifts

This week’s episode is about the net worth test and green card holders.

Specifically, let’s talk about someone who is a green card holder living abroad who has a net worth of $7,000,000.1 Our green card holder wishes to file Form I-407 and stop being a permanent resident of the United States.... continue reading

Expatriation
March 15, 2016 - Phil Hodgen

Why Social Security does not go on the Form 8854 balance sheet

Hello again from Phil. This is the bi-weekly Expatriation Only newsletter, in which we cover U.S. tax topics related to renunciation of U.S. citizenship or giving up your green card. You can stop getting this newsletter by clicking on the “Unsubscribe” link at the bottom of the email.

Why Social Security Isn’t an Asset

This week I am going to dive into the shallow pool of Tax Metaphysics and tell you why you do not put Social Security benefits on the Form 8854 balance sheet when computing your net worth.

I hope the answer aggravates you and (for those of you who can still vote in the United States elections) galvanizes your political views.... continue reading

Expatriation Tax and Trusts