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  1. PHil,

    This is confusing: “Compute the total U.S. income tax payable for 2015 (for herself and her husband) if she and her husband file “Married Filing Separately”. Remember, Ann, this means that all of the income you earn in the your new country of residence after you give up your green card will be completely non-taxable in the United States. ” —- This is confusing because when a long-term resident meet the substantial test and therefore treated as “resident alien” for tax reason and choose the status of “Married Filing Separately”, the income for resident alien who expatriated includes the “worldwide income” which is taxable at the final year of expatriation. Please take note that under the IRS ruling, when an individual is a “resident alien” for tax purposes, his/her income worldwide is subject to US tax . I don’t think that “married filing separately” only includes US income when the person is still considered a “resident alien” in the year of his/her expatriation.

    Please clarify Phil.

  2. Great article. It sounds as though Ann would also be considered a long-term resident and likely has a filing requirement for Form 8854 in 2015. I wouldn’t think the 6013(g) election would have any impact on the 8854 filing requirement. There could be other benefits to Ann remaining a non-resident depending on the tax rates for investment income in her country and her husband’s future plans regarding his U.S. citizenship.

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