Other Publications



U.S. Immigration Tax Planning – Covered Expatriates

Published in Taxes & Wealth Management by Thomson Reuters, Issue 9-1: February 2016. (p.14)

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Insights Vol. 2 No. 7: Updates & Other Tidbits

As Democrats and Republicans attempt to revamp the U.S. tax system, there is renewed discussion of lowering the corporate tax rate. In other national news, U.S. expatriation numbers are down in Q2 of 2015, the I.R.S. Transfer Pricing Operations Unit is officially here to stay, and three more banks agree to disclose activities to D.O.J.

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Pre-Immigration Income Tax Planning, Part II: Covered Expatriates

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Continuing on from our previous article concerning pre-immigration planning, this article will explain the tax rules by which an individual seeking to renounce his or her U.S. citizenship or green card status may be affected.

To relinquish U.S. citizenship or a green card, a formal act of relinquishment is required. Therefore, a green card holder who moves outside the U.S. will continue to be treated as a U.S. resident for tax purposes until he or she formally relinquishes green card status or it is rescinded by the government. A U.S. citizen residing outside the U.S. will have to formally relinquish his or her citizenship in order to be removed from the U.S. tax system. As a general rule, termination of U.S. residency becomes effective on the last day of the calendar year in which the status was relinquished. However, under certain circumstances, termination may be effective midyear.

Upon expatriation, should an individual be considered a “covered expatriate,” he or she may be subject to an exit tax, and following expatriation, any gifts and bequests made by such an individual may be subject to a succession tax in the case of U.S.-resident recipients.

For planning purposes, U.S. citizens wishing to relinquish their citizenship should determine if they are covered expatriates prior to undertaking any such action. Green card holders wishing to relinquish green card status must first determine if they are treated as long-term residents. If so treated, green card holders should determine if they are covered expatriates under the same tests applicable to U.S. citizens.

Expatriation the Transatlantic Way: Overview of the French and the U.S. Regimes

Over the past years, both France and the United States have recorded a growing number of individuals expatriating as a tax planning device.  In order to discourage these tax exiles, the French government introduced an exit tax in the late 90’s. The regime was later invalidated by the C.J.E.U. and reborn, in modified form, in 2011. Like France, the U.S. is no longer a tax paradise for those wishing to expatriate. In this article, guest author Nicolas Melot of Melot & Buchet, Paris, and Fanny Karaman compare the French and American exit tax regimes by giving an overview of their respective scopes and effects. For both U.S. and French purposes, the exit tax constitutes an important element in determining whether or not to expatriate.&

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