Most U.S. cross-border tax advisors concentrate on the income tax side of expatriation. In the year when U.S. citizenship or permanent residence is given up, a special “mark-to-market” income tax is imposed on certain “covered expatriates.” They must file Internal Revenue Service Form 8854 listing their worldwide assets and potentially pay a special exit tax on the appreciation in such assets in excess of a baseline exemption amount. This so-called “exit” tax is imposed at the highest U.S.
ARTICLE ACCESS REQUIRED
Please Log in if you are currently a Trust&Estates subscriber, or select DAYPASS for our new 24 hour access (nominal fee required).
If you are interested in unlimited article access for one year, please select Annual Subscription below.