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2010 Apr 12 – Bissell

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.

Written by usxcanada

12 April 2010 at 6:00 am

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