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  1. I believe that a dual citizen (USA plus another country) must enter the USA with the US passport. At least, this is what I have seen happen.

    After you renounce your US citizenship, travel to the USA will occur using your other passport.

  2. Hi,I’m new to this forum, but it looks interesting. Regarding the sheep and goat thread, if the “goat” had a second nationality (or to be honest, a primary nationality having left the US as an infant), is this still risky for travel to the US on this other passport ?
    Thanks in advance, David

  3. This amendment would take us back to the days of Section 877.

    Back then the IRS was on the receiving end of hundreds of Private Letter Ruling requests by taxpayers who didn’t want to be tagged as tax-motivated. This proposed law would take us back to those times.

    A covered expatriate is presumed to be tax motivated. But this presumption can be bypassed by asking for a ruling.

    I guess the people in Chief Counsel’s office are slacking off and need more work. The Esteemed Senator from New York must think so, anyway. If this passes, cue the avalanche of pointless PLR requests in 3 . . 2 . . 1 . . .

    Why doesn’t Shumer just take this to the logical conclusion? Once a US taxpayer, always a US taxpayer. There is no exit possible. That’s what he wants.

  4. Goats may be permanently barred if Reed, Schmuer, and Casey have their way:

    SA 1233. Mr. REED (for himself, Mr. SCHUMER, and Mr. CASEY) submitted an amendment intended to be proposed by him to the bill S. 744, to provide for comprehensive immigration reform and for other purposes; which was ordered to lie on the table; as follows:

    At the appropriate place, insert the following:


    Section 212(a)(10)(E) (8 U.S.C. 1182(a)(10)(E)) is amended to read as follows:


    (i) INADMISSIBILITY — The following aliens are inadmissible:

    (I) Any alien who is a former citizen of the United States who officially renounces United States citizenship and who is determined by the Secretary of Homeland Security to have renounced United States citizenship for the purpose of avoiding taxation by the United States.

    (II) Subject to clause (ii), any alien who is a former citizen of the United States and who is a covered expatriate.

    (ii) REVIEW FOR COVERED EXPATRIATES — A covered expatriate shall not be inadmissible under clause (i)(II) if the Secretary determines that the covered expatriate has established by clear and convincing evidence that avoiding taxation by the United States was not one of the principle purposes that the covered expatriate renounced United States citizenship.

    (iii) COVERED EXPATRIATE DEFINED — In this subparagraph, the term ‘covered expatriate’ means an individual described in section 877A(g)(1) of the Internal Revenue Code of 1986 and to whom section 877A(a) of such Code applies.

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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.