renunciation of US citizenship


P

Pico Rico

The IRS requires a mark to market the year you renunciate, assuming you meet
the income and net worth requirements. (Or should I say fail these
requirements?)

If assets are sold, money and residency moved offshore, have you escaped the
estate tax? Is the gain subject to capital gain rates per normal rules?

If assets are not sold, but residency moved offshore, are only the assets
remaining in the US subject to estate tax?
 
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S

Stuart A. Bronstein

Pico Rico said:
If assets are sold, money and residency moved offshore, have you
escaped the estate tax? Is the gain subject to capital gain
rates per normal rules?
If you are talking about non-citizens and non-residents, the answer
is yes. If you are talking about US citizens who give up their
citizenship and residence to avoid US taxes, the answer is no, at
least not for the ten years after they leave the US and give up
their citizenship.
If assets are not sold, but residency moved offshore, are only
the assets remaining in the US subject to estate tax?
Assuming you are talking about those who were never US citizens,
and who have given up residence, the answer is yes.

On the other hand deductions from the estate tax for non-citizen
non-residence are based on a proportion of world-wide deductions to
world-wide assets. If worldwide assets and deductions are not
disclosed, no deductions are allowed.
 

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