Understanding U.S. Expatriation and the IRC 877A Exit Tax
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Gain a better understanding of the impact of new tax law on expatriation, issues under section 877A and following the US Tax regime.For a variety of reasons, individuals may consider expatriating from the United States. Often, however, they fail to consider the potential income, estate and inheritance tax consequences of expatriation. Without careful consideration and proper planning, individuals may unintendedly subject themselves to the punitive exit tax or a continuing U.S. tax liability if the appropriate forms are not properly filed. This topic helps practitioners understand the mechanisms relating to tax expatriation from the United States. Through an understanding of the net income and net wealth test, a client can be properly advised as to the tax impact of their decision to leave the United States. Additionally, proactive planning can assure an individual properly expatriates and minimizes exposure to the exit tax.
AuthorsDatan Dorot, Dorot & Bensimon PL Dustin Sher, Dorot & Bensimon PL
Who Is an Expatriate?
• Are You a Covered Expatriate?
• Net Income Test
• Net Worth Test
• Income Tax
• Estate Tax
• Inheritance Tax
Planning and Other Considerations
• Avoiding Classification as a Covered Expatriate
• How to Expatriate