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  1. Just for the info, I just found out that my second country doesn’t tax inheritances coming from abroad.

  2. Also worth looking at what can happen to the next generation.

    Suppose the now-renounced previous dual-citizen passes on this $10mm to her children. Suppose they are US or dual citizens. And suppose she is a covered expatriate for some reason. Now her children, the grandchildren of the original bequester, will suffer section 2801 tax, even though she did not. Unless they too renounce, that is.

    In practice then, section 2801 encourages someone to renounce early. Before, rather than after, receiving an inheritance (or any other large step up in assets), so that they themselves do not become covered expatriates. And it potentially encourages entire families to go, not just one or two individuals.

    What a stupid law.

  3. Ooh, you’re fast, thanks!

    So, if the US doesn’t tax it, (let’s assume we’re under 10 million here) will the country of residence of the expat then tax the incoming $$ as a normal inheritance under their law? I know this varies by country, but tax treaties must address this sort of thing.

    I guess I have to find someone in ****** 🙂 to sort this out, because a quick look at inheritance tax rates here has got me good and worried that they will make off with nearly half, which doesn’t seem fair.

    Thanks for addressing this. You seem like a good guy.


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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.