Expatriation Tax Lawyers Blog

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Allocation of the Exclusion Amount 877A Calculating Exit Tax Allocation of the Exclusion Amount 877A Calculating Exit Tax: When it comes time for expatriation from the United States, some U.S. persons who are considered a covered expatriate may have to compute the exit tax. And, when it comes time to computing the exit tax, one important aspect is the exclusion of a certain portion of the mark-to-market unrealized gain. When a person computes the exit…
Specified Tax Deferred Account Expatriation Tax Exception Specified Tax Deferred Account Expatriation Tax Exception: The Specified Tax Deferred Account Expatriation Tax Exception (IRS 877A)  is complicated. In general, when a person expatriates from the U.S.,  and they are considered a covered expatriate, then they are subject to U.S. tax on the unrealized gain – using a Mark-to-Market calculation. As with anything dealing with the IRS, there are exceptions, and more exceptions.  One…
Deferred Compensation Expatriation Tax Treatment Deferred Compensation Expatriation Tax Treatment: We summarize Deferred Compensation Expatriation Tax Treatment. The Expatriation rules are complex. When a person is ready to expatriate, and learns they are a covered expatriate, the first step is usually to (immediately) take stock of their worldwide assets to determine the mark-to-market outcome on unrealized gain. This article will discuss the deferred compensation rules. Deferred Compensation Expatriation Tax Treatment (IRS) Some assets held…
Relief Procedures for Certain Former Citizens: How to Apply to the IRS Relief Procedures for Certain Former Citizens: The IRS Relief Procedures for Certain Former Citizens helps current and former citizens and residents with expatriation and U.S. exit tax avoidance — by avoiding covered expatriate status. Whether you have already relinquished U.S. Citizenship, or are intending to in the near future, this new program may be a good fit. It provide a tax-free option for…
Green Card Exit Tax 8 Years Green Card Exit Tax 8 Years & Tax Implications at Surrender: The Green Card Exit Tax 8 Years rules are complex. The IRS rules involving U.S. exit tax for green card holders is complex. The general proposition is that when a U.S. citizen renounces citizenship and relinquishes their U.S. status, they are subject to the expatriation and exit tax rules. But, the rules are not limited to U.S.…
IRC 877A IRC 877A: The language of IRC 877A code section (aka Internal Revenue Code Section 877A) is complex, and the IRS rules are even more complicated. Expatriation is the process of relinquishing U.S. person status. The expatriation rules apply to U.S. Citizens and Long-Term Permanent Residents (aka Long-Term Residents). Once a person expatriates, presuming they are a Covered Expatriate, they may become subject to the Exit Tax. The Exit Tax calculation is…
Form I-407 (Voluntary Abandonment of Legal Permanent Residence) Form I-407 Voluntary Abandonment of Legal Permanent Residence: The Form I-407 Voluntary Abandonment of Legal Permanent Residence process is relatively simple USCIS Form. The I-407 Form is required to abandon or relinquish a legal permanent resident’s  U.S. person status. Merely allowing the green card to lapse or expire does not per se end the person’s U.S. status. The U.S. government wants to keep track of individuals and…
Form 8854 & Instructions: Permanent Residents & Citizens Form 8854 Instructions: The IRS Form 8854 and Form 8854 Instructions can be complicated. U.S. Citizens and Permanent Residents who are considered long-term residents file IRS Form 8854. The 8854 form is filed in the year after expatriation. For example, if a Long-Term Resident relinquishes citizenship in 2019, then in 2020 when he files his 2019 tax return, he includes the Form 8854. We have summarized the Form…
Covered Expatriate: U.S. Exit Tax when You Relinquish? (Golding & Golding, Board Certified Tax Specialist) Covered Expatriate: A covered expatriate is a legal term that applies to certain U.S. persons at the time of expatriation. When a person is a covered expatriate, they may become subject to exit tax at the time of expatriation. These rules apply to U.S. citizens, and Legal Permanent Residents (Green Card Holders) who qualify as Long-Term Residents. The IRS requires…
U.S. Exit Tax U.S. Exit Tax: The Exit tax occurs from U.S. persons at the time of expatriation from the United States. If a person is a U.S. Citizen or Long-Term Resident covered expatriate, the exit tax calculations kick-in. At that time, the covered expatriate will evaluate their potential tax liability had they sold all of their assets on the day before expatriation. Most of the calculations are handled on a Mart-to-Market basis, with some…