As of the expatriation date, the individual continues to be a citizen of, and is taxed as a resident of, the other country; and
7701(b)(1)(A)(ii) for not more than 10 tax years during the 15-year tax period ending with the year of expatriation.
The deemed-sale rules under the mark-to-market regime require a taxpayer to compute gain or loss on worldwide assets on the day before the expatriation takes place.
83, an amount equal to the present value of the covered expatriate's deferred compensation is treated as having been received on the day before the expatriation date.
a nongrantor trust) immediately before the expatriation date.
The time period for acquiring a property in an involuntary conversion or a like-kind exchange is terminated on the day before the expatriation date.
residence to provide a statement to the IRS for the tax year of expatriation that includes the following information:
The IRS created Form 8854, Initial and Annual Expatriation Information Statement, to comply with Sec.
The date of expatriation must be included on the form.
Nonresident Alien Income Tax Return, when reporting the expatriation tax.
In May 2009, the IRS issued Form W-8CE, Notice of Expatriation and Waiver of Treaty Benefits, which covered expatriates are required to complete and provide to a payer if they had any of the following on the day before their expatriation date:
The Form W-8CE must be filed with the payer within 30 days of the expatriation for each specified tax-deferred account, item of deferred compensation, or interest in a nongrantor trust.