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  1. Sell the property and do not repatriate the money just like big US corporations.

    US citizens with a foreign place of birth have the upper hand with the IRS.

    Especially if the US is a short term stay.

  2. Worth noting that this is probably a very common case. You use investment land as your example, but any immigrant to the US who came more than two years ago and still owns their primary residence in their former country will face this issue. And it’s one that eventually builds up to a massive motivation to leave the US.

    Assuming they want to (or must) eventually sell this asset at some future date, your example green card holder is sitting on a US capital gains tax timebomb, one that gets larger as the asset appreciates over time. However, they can defuse it by simply surrendering the green card and leaving. For the globally mobile (and these people have moved country at least once already) there is eventually a point where the tax cost to stay in the US, even on this one asset alone, outweighs any benefit. US capital gains tax on $190,000 saved. Not insignificant. A right-thinking immigrant will be outraged at having to pay the US anything for gains accrued from long before they set foot in the US.

    The extra dimension added by the spectacularly bad policy of the Exit Tax is that when our example green card holder gets close to but not yet covered (time in the US, assets) then they’re now being practically begged by tax rules to depart from the US immediately, and wait no longer. Exit Tax saved on a pretend $100,000 gain. Again, not insignificant.

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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.