We use cookies to give you the best online experience. By using our website you agree to our use of cookies in accordance with our cookie policy. Learn more here.Close Me
When specific U.S. tax payers choose to expatriate, they can
face significant tax consequences and must also consider a number
of other issues. Hunter Norton, Tax Director at accounting firm
Farkouh, Furman & Faccio in New York explains U.S. expatriation
tax rules which apply under Internal Revenue Code (IRC) section
877A.
Expatriation from the U.S. has been growing since 2010, with
taxpayers choosing to expatriate for different reasons: "Most
commonly, it involves long-term U.S. permanent residents whose net
worth is growing and who have an interest in residing outside of
the U.S. in the future. It may also involve U.S. citizens who
reside in a different jurisdiction who want to avoid the tax
compliance obligations that apply to all U.S. citizens whether they
reside in the U.S. or not."
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
To print this article, all you need is to be registered on Mondaq.com.
Click to Login as an existing user or Register so you can print this article.
The main pitfall of owning a property located in the US is the potential exposure to the onerous US federal tax system. Using a structure can help in this regard.
U.S. persons (U.S. citizens or green card holders) living in Canada or abroad who have investments outside the U.S. should be aware of the potentially onerous tax filing requirements...
The Trump Administration, in collaboration with the House and Senate, has introduced a Framework for tax reform legislation that could bring sweeping changes to U.S. tax laws.
One of the most publicized and long-awaited business provisions contained in the Omnibus Budget Reconciliation Act of 1993, P.L. 103-66, 107 Stat. 312 (1993) (the "1993 Act") was section 197 of the Internal Revenue Code of 1986 (the "Code"), which governs the tax treatment of acquired intangible assets. However, section 197 cannot be analyzed in isolation. Since it comes into play whenever there is an allocation of consideration to an amortizable section 197 intangible, a basic understanding of
As part of the "Unified Framework for Fixing Our Broken Tax Code," President Trump and Congressional Republicans plan to repeal the "death tax" – a controversial tax that affects the wealthiest .002% of Americans.
As retirement plan processes continue to be more automated, such as enrollments, deferral changes, distributions, loans, etc., many plan sponsors encourage 401(k) plan participants...
Four years after the OECD and G20 countries adopted a 15-point action plan to attack base erosion and profit shifting (BEPS), a new era of international taxation was launched on June 7 when 68 countries signed a multilateral instrument.
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Where Will A U.S. Company With Foreign Earnings Pay Tax? (Video Content)
