International Wealth Planning

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

By: Jerald David August

Chair, International Taxation and Wealth Planning Group

 

Set of Expatriation Blog Posts

This is the third in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth the U.S. approach to the expatriation of a U.S. citizen and long-tern resident prior to the effective date of the Heroes Act of 2008 which applied to expatriations occurring after June 16, 2008.… Continue Reading

By: Jerald David August

Chair, International Taxation and Wealth Planning Group

Set of Expatriation Blog Posts

This is the second in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth the U.S. approach to the expatriation of a U.S. citizen and long-tern resident prior to the effective date of the Heroes Act of 2008 which applied to expatriations occurring after June 16, 2008.… Continue Reading

By: Jerald David August

Chair, International Taxation and Wealth Planning Group

Introduction of Set of Expatriation Blog Posts

This is the first in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth an introduction into the minefield of tax and non-tax considerations for an individual to consider, with the advice of US and foreign legal and tax counsel, on the merits and drawbacks of expatriation.… Continue Reading

The international business press has recently reported that India has promulgated stricter rules pertaining to tax evasion and related offenses in an effort to limit the number of investigations for tax evasion, including the willful non-disclosure of off-shore bank accounts, which result with taxpayers paying an additional fee in avoiding prosecution and a period of incarceration. In the past, Indian resident taxpayers who did not disclose their foreign bank accounts and other foreign investments required to be disclosed have also avoided prosecution by a special relief rule referred to as “compounding” with the Central Board of Taxes.… Continue Reading

In Martin Wächtler v. Finanzamt Konstanz, C-581/17 (CJEU 2/26/2019), the Court of Justice of the European Union (CJEU) determined that application of the German exit tax rules were incompatible with the Agreement on the Free Movement of Persons (AFMP) of June 21, 1999, between the EU and its member states on the one part, and between the EU and Switzerland on the other.… Continue Reading