PRACTICE AREA
Expatriation Tax Planning
Exit Tax Planning for U.S. Citizens and Long-Term Residents
Renouncing U.S. citizenship or relinquishing a green card after long-term residency triggers one of the most complex and consequential tax events in U.S. tax law — the exit tax under Section 877A. Without careful planning, expatriation can result in a deemed sale of all worldwide assets and significant tax liability. We guide clients through every stage of the expatriation process, from initial analysis through final compliance.
Our Services Include:
Covered expatriate determination and analysis
Exit tax modeling and mark-to-market gain calculations under Section 877A
Pre-expatriation planning to reduce or eliminate exit tax exposure
Planning for deferred compensation, pension benefits, and retirement accounts in the expatriation context
Eligible and ineligible deferred compensation item elections
Section 2801 planning for gifts and bequests from covered expatriates
Final-year U.S. tax return preparation (Form 1040-NR) and Form 8854 compliance
Planning for dual citizens and individuals who acquired U.S. citizenship at birth