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To: Horgad who wrote (67696)	2/14/2001 7:18:28 PM
From: Mark Adams	Respond to of 436258

If G7 works towards uniform codes and tax treaties, as I suspect they will, tax motivated relocation will diminish. I don't mind paying a fair share for the social support, but at times the complexity of compliance is frustrating. Thanks for the link; An extract from the article I'd read; Renouncing U.S. citizenship isn't a simple step. One process involves swearing a precise oath in the presence of a foreign-based U.S. consular. Another option is to become naturalized in another country with the intent of relinquishing U.S. citizenship. But in all cases, to be presumed free of major tax liabilities by the IRS, an individual's renunciation must be approved by the State Department's Office of Overseas Citizens Services, which then would issue a Certificate of Loss of Nationality. The IRS says anyone whose renunciation hasn't been accepted remains a U.S. citizen and therefore is liable for income taxes, regardless of how long they have lived abroad. The only option for people whose renunciations have been rejected by the State Department is to go to a U.S. court and prove that they intended to renounce their citizenship. Even if Mr. Rich was able to prove that he had successfully renounced his citizenship, he still could be liable. That is because tax laws long have required new expatriates to pay taxes on U.S.-related income for 10 years -- if the main reason they renounced was to avoid taxes. Congress in 1996 cracked down on expatriating tax dodgers by enacting a legal presumption that anyone with a net worth of more than $500,000 who gives up U.S. citizenship must be doing so to avoid taxes and therefore must pay taxes for the requisite 10 years. But that law wouldn't affect Mr. Rich since his renunciation attempt occurred in the early 1980s, so the onus of proving that he was trying to avoid taxes would be on the IRS. Citing privacy laws, IRS officials refused to comment on whether they are investigating the tax status of Mr. Rich or of his business partner and co-defendant, Pincus Green, who also avoided prosecution in Switzerland and was pardoned on Saturday. Likewise, State Department officials wouldn't say if either are still U.S. citizens. The question of the pair's citizenship and tax status has become the source of much discussion among federal law-enforcement agents involved in the global manhunt for Mr. Rich until he was pardoned. Some of them have discussed the matter in recent days informally with IRS officials, said one former agent involved in those talks. "As far as I know, the government never has recognized Rich's renunciation of his American citizenship," this former agent said. This individual said he was present at a 1982 meeting in which Justice Department and IRS attorneys decided to oppose accepting Mr. Rich's surrender of citizenship. Currently, however, "the IRS has yet to determine what Rich's status actually is," he added.