USCIS Update: Citizenship, Denaturalization, Tax Compliance, Moral Character

In recent months, several seemingly unrelated developments in U.S. law and policy have begun to converge in a way that should capture the attention of tax professionals, immigration lawyers, and globally mobile individuals. On one front, the Department of Justice continues to press denaturalization cases against U.S. citizens who obtained their status by fraud or … Continue reading USCIS Update: Citizenship, Denaturalization, Tax Compliance, Moral Character →

Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax

In the heart of America’s immigration debate, a lesser-known but seismic issue is emerging. The intersection of denaturalization and the expatriation tax regime is an explosive topic that has not yet been explored. If the expatriation regime applies to a denaturalized citizen, it imposes an exit tax through a deemed sale of worldwide assets as … Continue reading Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax →

Covered Expatriates, Exit Tax and the Principal Residence

My earlier blog post discussed the rules that apply to a US taxpayer who sells his personal residence, whether located abroad or in the US. If the home qualifies as the “principal residence” and other requirements are satisfied the taxpayer may exclude up to US$250,000 ($500,000 for joint returns) of taxable gain from income. As … Continue reading Covered Expatriates, Exit Tax and the Principal Residence →

Expatriation – IRS Told to Get Tough and Enforce the Law

The Treasury Inspector General for Tax Administration (TIGTA) recently issued its report “More Enforcement and a Centralized Compliance Efforts Are Required for Expatriation Provisions”, (Reference Number: 2020-30-071, September 28,2020) telling the Internal Revenue Service (IRS) that it needs to do more to make sure that the rising number of US citizens and long term residents … Continue reading Expatriation – IRS Told to Get Tough and Enforce the Law →

Expatriation: Deferring Payment of the Exit Tax

I recently blogged about the debate between Prof. Edward Zelinsky and John Richardson as it pertained to the Exit Tax imposed on so-called "covered expatriates". This was in the broader context of the US income taxation model which is based on one's "citizenship" rather than one's residence. The thrust of my earlier blog post concerned … Continue reading Expatriation: Deferring Payment of the Exit Tax →