Publications
Expatriation Tax Planning
“The Exit Tax’s Inconsistent Treatment of Trusts” 49 Bloomberg Tax Management International Journal No. 11 (November 6, 2020)
The Heroes Earnings Assistance and Relief Tax Act of 2008 (the “HEART Act”) reformed the income, gift, and estate tax treatment of United States citizens who relinquish their citizenship and long-term U.S. residents who cease to be lawful permanent residents within the meaning of §7701(b)(6) (“expatriates”).
“Tax Relief for Certain Expatriates: Tax Compliance After the Fact” 48 Bloomberg Tax Management International Journal No.11 (November 8, 2019)
On September 6, 2019 the Internal Revenue Service announced the terms of a new procedure which will allow certain former United States Citizens to avoid covered expatriate status (the “Relief Procedure”).
“Look Before You Leap: When Renouncing U.S. Citizenship May Not Be a Good Idea” 46 Bloomberg BNA Tax Management International Journal 219 (April 14, 2017)
For those advising U.S. citizens living and domiciled abroad, renouncing United States citizenship may appear a no-brainer.
“Advising US Citizens and Long-Term Residents on Expatriating” 9 Trust Quarterly Review, No. 3 (September 2011)
The exit tax of section 877A is potentially applicable not only to U.S. citizens, but also individuals who have resided in the U.S. for at least eight out of 15 taxable years (long-term resident).