Avoid U.S. Taxpayer Status After Expatriation

This week’s question came from reader O. He asks about expatriates returning to the United States and a way in which an expatriate might become a U.S. taxpayer again–by spending too much time in the United States.

Hi Phil,

I liked your blog post on the Substatial Presence Test : Max 183 days/year or 121 days/year for consecutive years ;-). http://hodgen.com/the-substantial-presence-test-explained/

My question is, is there a different rule for expatriates? It seems that under section 877, those who expatriated between 2004 and 2008 have a 30 day limit per year in the 10 years after expatriation. I don’t see this after 2008, so I assume this restriction no longer applies. Is this also your interpretation?

Income Taxation of a Covered Expatriate’s 401(k) Plan

Online Workshop For Noncovered Expatriates – 16 and 23 January 2015 We are running our patented Online Workshop for Noncovered Expatriates starting this Friday. There are two sessions (January 16 and January 23), each 90 minutes, but last time we did it we ran probably double that length. We stick around until we answer every […]

Covered Expatriates and Their IRAs After Expatriation

This week we look at covered expatriates and IRAs after expatriation. How do IRAs behave after expatriation? How are distributions taxed? What is the strategically best choice–keep your money in the IRA or close it, take the
money, and run?

To keep things relatively short, I am only going to talk about regular IRAs.

Roth IRAs and Covered Expatriates

This week’s question is about Roth IRAs and covered expatriates. It comes from reader R, who said he is a covered expatriate. Lightly edited, his question is:

One of my accounts is a Roth IRA, funded many years ago but now grown to about $40,000. What happens to this? I over 59.5 years old and can withdraw the money tax-free before I expatriate. Might the protection of that end once I expatriate, in which case, should I make tax free withdraw now, before expatriation?

Webinar for Noncovered Expatriates

The objective of the webinar will be to help you completely understand the tax paperwork you need to prepare in order to properly renounce your U.S. passport and NOT be a covered expatriate. Participation is limited to 10 individuals!

Death as an exit tax avoidance strategy, part 2

This week's episode was written in stages. I started writing this while sitting in Seat 25C on U.S. Airways flight 865 en route to Sint Maarten. I rarely fly U.S. Airways, because the planes are usually well worn. It's like riding a bus. On this flight, two of the three seat trays in row 25 […]

Death as an exit tax avoidance strategy, part 1

This Week This week's question comes from Daniel Hayden, a German tax lawyer I know. He is a fountain of interesting ideas. Hi Phil, Here is another question, that – as far as I remember – has not been covered in your question-of-the-week-emails: Is there any exit tax, if a green card holder, who returned […]

Avoid Bern

A report from the front: Dear Phil: I have been living in Switzerland for the last 20 years; and after much self-deliberation, I finally decided to return my US passport.  It is now impossible to have the necessary bank accounts for daily living here as a result of the FATCA legislation. I tried to obtain […]

RRSPs and the certification test–a solved problem

This Week This week’s question comes from reader M, who has an RRSP question. My keen analytical mind tells me she lives in Canada.    (For those of you who are not Canadian, an RRSP is a self-funded retirement savings plan much like the IRA in the United States). This question is particularly apt because […]

Give up green card, make an election to file a joint tax return

This Week Hello from Seat 12B on AC790: Los Angeles to Toronto. Middle seat yay. Sunday morning. For a good Sunday song, go find Kris Kristofferson's "Sunday Morning Coming Down" and take a listen. Bonus points for finding the version with Steve Earle. (YouTube). There are other versions, but that's the one I like. The […]