Estate Planning Considerations for Dual Residents
High net-worth individuals and certain long-term green card holders who relinquish their U.S. citizenship or green cards, or so-called covered expatriates, may be subject to an immediate exit tax, an income tax liability under I.R.C. § 877A; and a special transfer tax under I.R.C. § 2801 (the “2801 tax”). This white paper reviews what defines an expatriate and covered expatriate and discusses the exit tax and offers planning points for pre- and post-expatriation gifting.
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