Page 60 - International Taxation IRS Training Guides

Expatriation

 An “expatriation tax” is imposed on certain individuals

citizenship or end their U.S.
who relinquish their U.S.

resident (green card
lawful long-term permanent

holder) status:

applies only to certain high-income or high-net
• Generally
worth
individuals, but can apply to anyone who fails to
certify under penalties of perjury U.S. federal tax
properly
preceding 5 years.
compliance for

• Exceptions
for certain dual citizens, but must still certify
compliance.

• Is
a one-time tax on the unrealized gain of all property of the
expatriate
(regardless of location), calculated as if the
property
had been sold at its FMV on the day before the
expatriation
date.

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