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The new expatriation tax law, effective for calendar year 2009, defines "covered expatriates" as expatriates who have a net worth of $2 million, or a 5-year average income tax liability exceeding $139,000, to be adjusted for inflation, or who have not filed an IRS Form 8854 [20] certifying they have complied with all federal tax obligations for ...
The American Bar Association's Taxation Section believes 26 U.S.C. § 6039G should be read not to require persons whose loss of citizenship occurred before the passage of the American Jobs Creation Act of 2004 to file the exit tax form (Form 8854), and has urged the issuance of Treasury regulations clarifying this interpretation. [19]
The Ex-PATRIOT Act was a proposed United States federal law to raise taxes and impose entry bans on certain former citizens and departing permanent residents.The law would automatically classify all people who relinquished U.S. citizenship or permanent residence in the decade prior to the law's passage or any future year as having "tax avoidance intent" if they met certain asset or tax ...
Names of those renouncing in the last months of the year will mostly appear on the list before they have filed IRS form 8854 establishing covered or non-covered status, so it does not seem possible that the list is only required to contain covered expatriates. [60] [61] [62] [63]
A tax exile is a person who leaves a country to avoid the payment of income tax or other taxes. The term refers to an individual who already owes money to the tax authorities or wishes to avoid being liable in the future for taxation at what they consider high tax rates, instead choosing to reside in a foreign country or jurisdiction which has no taxes or lower tax rates.
The United States does not want to surrender citizens that can provide continual tax income, and the barriers in place are designed to make renouncing citizenship a costly affair for years to come.