Tag Archives: Succession Tax

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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Expatriation: Succession Tax

December 17, 2012  |   Posted by :   |   Expatriation   |   0 Comments

IRC Section 2801 IRC Section 2801 imposes a succession tax (at the highest applicable gift or estate tax rates), on the receipt by a U.S. person (i.e., citizen, resident alien) of a “covered gift” (i.e., a gift from a “covered expatriate”, IRC Section 877A). The succession tax applies to gifts from individuals who expatriate on […]

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Expatriation: Green Card Holders

December 05, 2012  |   Posted by :   |   Expatriation   |   0 Comments

The Heroes Earnings Assistance and Relief Tax Act of 2009 (“HEART”), P.L. No. 110-245, adds new IRC Sections: 877A (imposing a “mark to market tax” on asset “sale” net gains) and IRC§2801 adding a “succession tax” (on the receipt by a U.S. person of a gift from a “covered expatriate”.) Based upon these new taxes, […]

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