News & Analysis as of

Exit Tax Internal Revenue Service

Rivkin Radler LLP

Swapping Foreign Real Properties On a Tax Deferred Basis

Rivkin Radler LLP on

Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more

Gray Reed

It’s So Hard to Say Goodbye to USA: Expatriation and the IRS

Gray Reed on

Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces...more

Bilzin Sumberg

Breaking Up Is Hard To Do: A Quick Refresher on the U.S. Tax Implications of Expatriating

Bilzin Sumberg on

Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more

Patterson Belknap Webb & Tyler LLP

Who Is a U.S. Person? Disparities Between U.S. Tax and Immigration Law

The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more

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