ARTICLE
14 December 2015

US Citizenship Renunciation – Inheritance Tax Proposal Update

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Moodys Private Client Law LLP

Contributor

Moodys Private Client Law is part of Moodys Private Client and home to a team of Canadian and US lawyers dedicated to simplifying the journey ahead for individuals and businesses. We take pride in seeing every detail, anticipating every obstacle and relying on our global, multidisciplinary expertise to chart the best path forward for your individual situation and ensure success. Focused on the areas of business law, immigration, trust and estate law, and tax law, our goal is to ensure you and your business are covered from every angle.
In September 2015, the IRS issued proposed regulations to section 2801 of the Internal Revenue Code that would introduce a steep tax for US citizens who receive property from certain persons who renounced their US citizenship and are considered "covered expatriates".
United States Tax

In September 2015, the IRS issued proposed regulations to section 2801 of the Internal Revenue Code that would introduce a steep tax for US citizens who receive property from certain persons who renounced their US citizenship and are considered "covered expatriates". Our firm's Roy Berg and Kevin Kirkpatrick wrote about such proposals, and their blog provides excellent background information regarding these proposals.

On Dec. 9, 2015, Roy Berg, Paul Barba, and Kevin Kirkpatrick submitted our firm's comments to the IRS regarding the proposed regulations to section 2801 and will be providing oral comments to the IRS at a hearing in Washington, D.C., on Jan. 6, 2016. We are honoured to have the opportunity to assist the IRS in the development of regulations in this very complex area of the law.

Moodys Gartner Tax Law is only about tax. It is not an add-on service, it is our singular focus. Our Canadian and US lawyers and Chartered Accountants work together to develop effective tax strategies that get results, for individuals and corporate clients with interests in Canada, the US or both. Our strengths lie in Canadian and US cross-border tax advisory services, estateplanning, and tax litigation/dispute resolution. We identify areas of risk and opportunity, and create plans that yield the right balance of protection, optimization and compliance for each of our clients' special circumstances.

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.

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