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Jul 1, 2008 12:00 PM
Fleece the Fleeing
Giving up a U.S. passport carries a hefty new price tag. A new law subjects certain individuals who expatriate or give up their green cards to immediate tax on the inherent gain on all of their worldwide assets and a tax on future gifts or bequests made to U.S. citizens or residents. Trustees of non-grantor trusts with beneficiaries who expatriate are required to withhold tax from certain distributions and pay the tax over to the Internal Revenue Service. These onerous and far-reaching obligations can mean a life-long relationship with the United States that will require planning long after the expatriation has taken place.
Tax practitioners have been sounding like the boy who cried wolf in recent years. They kept sounding the alarm that Congress was about to enact legislation aimed at U.S. citizens who expatriate, but Congress repeatedly failed to act on its threats. Then Congress finally did it. In late May, federal lawmakers unanimously passed the Heroes Earning Assistance and Relief Tax (HEART) Act, which provides tax relief for active duty military personnel and reservists. The law also takes direct aim at expatriates.
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| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
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