People planning to expatriate can do a number of things to avoid this result. German citizen’s failure to establish that he was a resident of Germany meant that he was a “covered expatriate” for Sec. 877A purposes and therefore liable for tax on stock sale gains that would otherwise have been exempt under the United States–Germany tax treaty. To read the full article in The Tax Advisor, click: Failure to Abandon U.S. Residency Leads to Tax Liability.
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The IRS issues long-awaited rules on taxation of gifts and bequests from covered expatriates. Sally P. Schreiber, Journal of Accountancy senior editor, discusses the recently proposed regulations and what’s to be expected. To find out more on the AICPA’s article, click: Proposed rules govern taxation of gifts and bequests from covered expatriates.