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Archive for March 2010

2010 Mar 19 – Martin

 
Eileen Martin / Elizabeth Buscaglia
Border crossings trip up travellers with latent tax liabilities
Lawyers Weekly (19 Mar 2010) 10

http://www.hodgsonruss.com/Home/Practice_Areas/Alphabetical_Listing/Immigration/Articles/EileenMMartinandElizabethKBuscagliaonBorderCrossingandTaxLiabilities

The Western Hemisphere Travel Initiative effective 1 June 2009 may affect extraterritorial US citizens seeking to enter the United States. “What begins as an innocent-sounding requirement — to travel on a U.S. passport or obtain a CLN [Certificate of Loss of Nationality] — can have serious tax consequences and preclude a former citizen’s ability to enter the U.S. for the rest of her life.”
 

Written by usxcanada

19 March 2010 at 6:00 am

2010 Mar # – Packman

 
Kevin E. Packman / Summer A. LePree
IRS provides some guidance on the new expatriation exit tax
Journal of Taxation 112:3 (Mar 2010) 145-153

Not online.

The Heroes Earnings Assistance and Relief Tax Act of 2008 ended subjection of citizenship renouncers to “an alternate U.S. income tax regime for ten years following the date of expatriation. … It is clear that the U.S. intends to expand the tax base by using all available estate tax inclusion provisions and denying the use of any provisions that otherwise would reduce the tax base.”
 

Written by usxcanada

1 March 2010 at 6:00 am

Posted in Academic, Uncategorized