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