Similar Posts

5 Comments

  1. @chase,

    If you don’t meet any of the three tests, then you aren’t subjected to the expatriation rules at all. This means that the Section 877(g) rule (“If you spend more than 30 days in the USA in a following year, then you’re a tax resident for all purposes”) does not apply to you.

    In other words, failing the 3 tests is a good thing. 🙂

    /Phil

  2. What happens if you don’t meet any of the 3 tests under 877, are you allowed to visit more than 30 days?

  3. The Covered Expatriate status may be unconstitional for
    estate tax purposes and somebody should stand for that in front of
    the supreme court. How come someone with a net worth 2 M$, his
    estate will be taxed from the first dollar at whatever the estate
    tax rate is at the time? Phil, what’s your take on this?

  4. The Covered Expatriate status may be unconstitional for estate tax purposes and somebody should stand for that in front of the supreme court.
    How come someone with a net worth 2 M$, his estate will be taxed from the first dollar at whatever the estate tax rate is at the time?
    Phil, wht’s your take on this?

  5. There are tax-compliant strategies to help mitigate or eliminate expatriation taxes. One such strategy is the exchange of assets for a foreign deferred variable annuity policy. It may be possible for Alice to sell her home, buy a foreign annuity and avoid the exit tax. The annuity policy would not be subject to the new expatriation tax because the annuity policy, like a life insurance policy, is not an appreciated asset.

    Happy new year, Phil.

Comments are closed.

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.