Archive for April 2010
Why more U.S. expatriates are turning in their passports
Time World (20 Apr 2010)
The “drastic and irrevocable step” of giving up US citizenship is “one that an increasing number of American expats are willing to take.” Ben from Chicago in Australia has cut the tie, and John in Switzerland is contemplating doing likewise. Tax attorney Phil Hodgen says, “More and more people see no long-term benefit to retaining U.S. citizenship.”
Thomas St.G. Bissell
An “exit tax” enters the U.S. tax lexicon — §877A and guidance under Notice 2009-85
Tax Management Memorandum 51:8 (12 Apr 2010) 123-135
No link available.
A technical article with 51 footnotes by a tax lawyer. The IRS Notice estimated an annual renunciation of “approximately 100 taxpayers.” The new rules introduced by the HEART Act of 2008 apply “to an individual whose ‘expatriation date,’ as specially defined in the law, is after June 16, 2008.” The new Form 8854 applies to expatriations subject to §877 before 17 June 2008 as well as to expatriations after that date subject to §877A.
Ten facts about tax expatriation
Artio Partners (1 Apr 2010)
“An accounting and business advisory firm in Chicago” offers a summary of taxation aspects associated with loss of U.S. citizenship.