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Expatriation as an Out-of-Body Experience: Part II

Pitfalls and planning for the dreaded U.S. inheritance tax

In Part 1 of our article, which appeared in the November 2019 issue of Trusts & Estates, we began our discussion of the U.S. inheritance tax under Internal Revenue Code Section 2801, which can follow U.S. expatriates for many years after they leave the United States. Our article included some tips on how to plan for this dreaded tax. We’ll now offer some other strategies for helping clients, who have or are contemplating expatriation, avoid the tax. 

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