Expertise   /   Expatriation



U.S. citizens and permanent residents pay income tax on their worldwide income.  If sufficiently wealthy, their worldwide assets are taxed when they die.  This is true no matter where they live. Every year, more and more people are relinquishing their U.S. citizenship or giving up their green card (permanent resident) visa status.

This means that they are leaving the U.S. tax net. As they leave, the United States seeks its last chance to impose tax. This is called the “exit tax.” Section 877A of the Internal Revenue Code.

If you are rich enough (as defined by the U.S. government) or your tax paperwork is not in order, the Internal Revenue Service pretends that you sold everything you own on the day before you relinquished your citizenship.  After applying an exemption amount ($651,000 in 2012) you pay tax on the “pretend” sale. The Internal Revenue Service pretends that you received all of your IRA balances on the day before you relinquished your citizenship.  That’s all taxable income to you.

There are a number of other special tax rules that may create an enormous tax liability to the United States, just because you gave up your U.S. citizenship or green card visa. Even if you are not rich (again, “not rich” is defined by the U.S. government, not by you), you will still face a mountain of tax paperwork that needs to be filed correctly and on time.

We know these tax rules, perhaps better than anyone else, because we counsel so many people throughout this process.  Let us help you – from your initial questions when you first consider this action, through the tax planning before you relinquish citizenship, and filing the tax returns afterwards.

Recent Articles on Expatriation

May 10, 2016

Tax Residency Starting, Termination Dates for Green Card Holders

Hey there fellow expatriation aficionados. Phil here with the every-other-Tuesday Expatriation Only newsletter. You can unsubscribe by clicking the “unsubscribe” link at the bottom of this email. Simple Facts Meet Dumb Systems This week is…continue reading

May 5, 2016

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…continue reading

April 26, 2016

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…continue reading

April 12, 2016

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…continue reading

March 29, 2016

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…continue reading

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