
Expatriation and the Exit Tax
Due to onerous US tax reporting and filing obligations as well as other considerations, there are US citizens and long-term greencard holders who wish to relinquish their US citizenship and long-term residency in favor of other jurisdictions. For “Covered Expatriates” expatriation may result in adverse tax consequences. In this WealthCounsel CLE, Eli Akhavan will discuss who qualifies as a “ Covered Expatriate,” the tax consequences of expatriation for a Covered Expatriate (the “Exit Tax”) and planning opportunities to minimize the tax bite. Special attention will be given to how a Covered Expatriate’s trust and estate planning will affected.
Topics to be discussed include:
- Mechanics of relinquishing US citizenship or long-term residency
- How does a person become a Covered Expatriate for tax purposes under the three tests:
1. Average tax liability
2. Net worth
3. Certification of compliance
- Exceptions to the definition of a Covered Expatriate
- Exit Tax consequences of becoming a Covered Expatriate
1. Mark-to-Market
2. Specified tax deferred account
3. Deferred compensation
4. Interests in nongrantor trusts
- Estate and Gift Tax consequences under Section 2801 for Covered Expatriates
- Planning strategies prior to expatriation
Presented by: K. Eli Akhavan, JD
CLE: 1.0 general credit
Approved States: AR, CA, CO, GA, IL, NJ, NV, NY, OK, PA, TN, UT, VT
(AK, AZ, CT, MO, ND, NH, TX eligible to claim credit)
We will supply you with the information needed to self-apply in other states.
Contact shopcle@wealthcounsel.com for CLE assistance.
WealthCounsel members: This CLE eligible program is complimentary for WealthCounsel members. Please access and view it here via the member website for optimal experience and inclusion in your CLE Profile Account.