Tax Consequences to Expatriation
270 W 43rd Street
New York, NY 10036
Discussion focuses on the various substantive income and transfer tax impacts to US citizens renouncing their US citizenship, as well as to long-term residents who return home or to another jurisdiction. A special “mark-to-market” realization event under Section 877A applies to “covered expatriates.” Planning options as well as traps for the unwary are highlighted.