By: Jerald David August
Chair, International Taxation and Wealth Planning Group
This is the fourth and last segment to the set of posts that summarizes the expatriation rules contained in the Internal Revenue Code. This last segment addresses exceptions to the mark-to-market rules under Section 877A and moves onto to address the somewhat overlooked succession tax under Section 2801.
Exceptions to the Mark-to-Market Tax Under Section 877A
The mark-to-market tax applies to most types of property interests held by the individual on the date of relinquishment of citizenship or termination of residency, with certain exceptions.… Continue Reading