Tag Archives: covered expatriate

Expatriation – Charitable Lead Trusts

April 11, 2013  |   Posted by :   |   Expatriation   |   0 Comments

Regarding U.S. persons who expatriate, classified as “Covered Expatriates”, if prior to expatriation they establish and fund a Charitable Lead Trust, open trust distribution, they (or their heirs) may be subjected to three separate taxes under the 2008 Tax Act (“HEART ACT”): Non-Grantor Trust (30%-Withholding Tax) (1) If the trust is a non-grantor trust, the […]

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Expatriation – Tax Reporting Form 8854

April 08, 2013  |   Posted by :   |   Expatriation   |   0 Comments

A covered expatriate must file an information return on IRS Form 8854 in each tax year he is subject to the mark-to-market tax. (IRC Section 6039G; IRS Notice 2009-85). IRS Form 8854 is used to provide notice that the individual has relinquished their U.S. citizenship or long-term residency status. Form 8854 is filed in addition […]

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Expatriation and the Ten Year Rule

March 20, 2013  |   Posted by :   |   Expatriation   |   0 Comments

Expatriates who left the U.S. prior to June 17, 2008 are covered under prior tax rules, contained in three separate Tax Acts, which each subject U.S. expatriates to a ten-year “alternative tax regime” on U.S. source income; i.e. for ten years after expatriation, the expatriate is required to file a U.S. income tax return, to […]

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Covered Expatriate – Covered Gifts

January 28, 2013  |   Posted by :   |   Expatriation   |   0 Comments

Covered Expatriate: Annual U.S. Income Tax Compliance A “covered expatriate” subject to annual U.S. income tax compliance must file IRS Form 8854 for: 1. Each year subject to mark-to-market tax; 2. Each year with deferred compensation items to certify either: no distributions received, or to report distributions received; 3. Each year elects to defer payment […]

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Expatriation: Covered Expatriate

December 10, 2012  |   Posted by :   |   Expatriation   |   0 Comments

A covered expatriate is an individual who either: 1) Relinquishes their U.S. citizenship; or 2) Terminates their long-term residency status after June 16, 2008. The act of expatriation, triggers two (2) taxes: 1)  Under IRC Section 877A, a “mark-to-market tax” is imposed on the expatriate taxing net gains on assets (in excess of $651,000 in […]

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