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May 2011 – Expatriation: Exit Tax, Planning Options, New Citizenship

February 14th, 2013

Expatriation refers to not simply leaving the U.S. and living abroad, but also to surrendering U.S. citizenship or permanent residency. If someone does surrender U.S. citizenship, moves abroad and picks up a new citizenship, the U.S. government may be unable to recover taxes due to it by the expat (no more jurisdiction). Consequently, the expatriation rules of the Code look to extract a tax from the expat while the U.S. still has jurisdiction. This is commonly referred to as the “exit tax.”

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