Each year, an increasing number of U.S. taxpayers, both U.S. Citizens and long-term residents, decide to renounce their citizenship. Expatriation is generally treated as a taxable event for federal (and sometimes state) income tax purposes so it can have dramatic income and transfer tax consequences as well as added compliance burdens. The tax impact can be particularly significant for high net-worth clients. For instance, those who hold interests in closely-held companies or real estate may face post-expatriation liquidity problems. Likewise, post-expatriation transfers, often from a U.S.-expatriate to a U.S. individual, can result in substantial inheritance-like taxes. To avoid potential pitfalls, individuals who pursue expatriation must carefully navigate Internal Revenue Code (IRC) Sections 877 and 877A and other relevant federal regulations.
On Tuesday, March 31, 2015, Jerald David August presented at the American Law Institute CLE Webcast Event, "To Renounce or Not? Tax Risks & Rewards of Expatriation"