Archive for October 2009
Terry Gilliam on Monty Python and renouncing America
ABCNews (22 Oct 2009)
Peter Travers interviews director Terry Gilliam who talks about his renunciation of US citizenship, apparently pre-2008.
Yu Hang Sunny Kwong
Catch me if you can: relinquishing citizenship for taxation purposes after the 2008 Heart Act
Houston Business & Tax Law Journal 9:3 (Fall 2009) 411-444.
No link available.
This seven-part article features 281 footnotes. Parts: (1) Brief introduction (2) Cultural and financial aspects of tax-motivated expatriation (3) History of relevant law (4) Present circumstances (5) Essence of the problem (6) Possible improvements on current legislation (7) Conclusion.
The history in part 3 covers: (a) Early history (b) Expatriation Act of 1868 (c) IRC §877 and Foreign Investors Tax Act of 1966 (d) Health Insurance and Portability and Accountability Act of 1996 (e) American Jobs Creation Act of 2004 (f) Legislation 2004-2008 (g) Heroes Earnings Assistance and Relief Tax Act of 2008.
Part 4 covers different tax categories (income, gift, estate, exit, succession) as well as considerations relating to immigration law.
Kwong addresses “the difficulty of enforcing the United States’ system on wealthy taxpayers with enormous resources, patience and influence.” Yet strong “cultural resistance towards tax-driven expatriates” ensures that legislators will continue to persist in attempting to close loopholes.
Kwong concludes: “The only reliable way to remove the incentive to the expatriates is to adjust the expatriation tax regime so that it is revenue neutral.”