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Article by Ellen Seiler Brody and Jason K.Binder*

Co Editors: Stanford H. Goldberg* and Peter A. Glicklich**

Introduction

With the passage of the Heroes Earnings Assistance and Relief Tax Act of 2008¹ ("the heart Act") on June 17, 2008, circumstances changed drastically for those individuals who were planning to give up their US citizenship and for long-term US residents who were planning to give up their green cards. This act, with its vetoproof name, was designed to provide tax relief for US soldiers. In order to pay for this relief, however, Congress imposed a new "exit tax" on Americans seeking to revoke their US citizenship.

The United States taxes its citizens on their worldwide income. The only way US citizens can legally avoid paying US taxes is to expatriate....

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