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December 6, 2016 - Phil Hodgen

U.S. Estate Tax After Expatriation

Hi and welcome to Expatriation Only, the newsletter devoted entirely to tax problems faced by people who give up their U.S. citizenship or green cards. You watched “escape” movies, right? This is all about the tax hurdles you face when escaping the U.S. tax system.

This episode was written in response to an email I received from reader D.O. Thanks for the questions. (Hint: you, too, can email me and I will answer your questions.)

Estate Tax After Expatriation

Let’s talk about estate tax. This is a tax imposed on what you own when you die. The tax rate caps out at 40%.... continue reading

November 22, 2016 - Phil Hodgen

Estate Tax for Noncovered Expatriates

Hello and welcome to Expatriation Only.

Noncovered Expatriates

Noncovered expatriates are people who – when they exit the U.S. tax system can answer “Yes” to all three of these questions:

  1. Is your net worth below $2,000,000?1
  2. Did you, on average over the previous five years, have a Federal income tax liability below $162,000?2
  3. Have you, for the previous five years, filed all of your required U.S. tax paperwork correctly and paid all of your U.S. tax?3

If you answer “no” to any one of those questions, you are a “covered” expatriate.4

Covered Expatriates and Punishing the Iniquitous

This discussion is only marginally accurate for covered expatriates – they face an additional bolus of tax rules designed to punish those who have sinned in the eyes of our Dear Leaders.... continue reading

November 8, 2016 - Phil Hodgen

Death and Taxes and Expatriation

I have not really focused on the estate tax side of expatriation in any great depth. This will be the first of several blog posts where you get 26 U.S.C. §877A and §2801 stuff every two weeks. Plus other bonus coverage of other §§ of the Internal Revenue Code.1

Why IRC Section2 2801 Exists

This week let’s talk about the unheralded PITA embedded in the tax rules that haunt covered expatriates.

U.S. persons who receive gifts or inheritances from covered expatriates will have the privilege of paying $0.40 of every dollar they receive as punishment for having been acquainted with someone who renounced U.S.... continue reading

October 25, 2016 - Phil Hodgen

How to be a Resident After You Renounce

Welcome to Expatriation Only, the biweekly newsletter about giving up U.S. citizenship and residence.

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Promoting Our Brand New Newsletter: Supers Only

We have a brand new newsletter: Supers Only. It is a companion to our newest website,, currently in soft launch.

The subject? Australian superannuations – the Australian pension plan.

The audience? We are publishing the newsletter for Americans living and working in Australia, and Australians living in the United States. These two groups have a non-obvious U.S. tax problem, and it needs fixing.

The problem? The U.S.... continue reading

October 11, 2016 - Phil Hodgen

Easy Math for Determining Long-Term Resident Status

Hello and welcome to Expatriation Only, the biweekly newsletter that focuses on people renouncing U.S. citizenship or giving up green cards.

This week’s edition was triggered by a query from a reader, who was unclear about how green card holders figured out whether the exit tax rules applied to them (or not).

The exit tax rules apply to expatriates. Citizens become expatriates by relinquishing U.S. citizenship. Immigrants become expatriates by (1) being immigrants for a long time, then (2) giving up their immigrant visa status.

Immigrants who hold their permanent resident visas (green cards) for long enough to be hit by the exit tax are called long-term residents.... continue reading