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Strategies & Market Trends : Mish's Global Economic Trend Analysis -- Ignore unavailable to you. Want to Upgrade?

To: Amy J who wrote (22112)	1/25/2005 6:25:18 AM
From: Elroy Jetson	Read Replies (2) \| Respond to of 116555

The way Congress wrote the law, the IRS must prove that your change in citizenship was motivated primarily by the desire to evade taxes. We would have to look at case law in the Tax Court to determine if there are those who have successfully argued their change in citizenship was not motivated by taxes. As a rule of thumb, the U.S. Treasury has said in print that they do not consider the change of citizenship to be "economic" for those with assets under $5 million. Whether this opinion influences the Tax Court I don't know. Certainly U.K. citizenship brings with it higher taxes, but residence outside of England removes that problem. I personally suspect that this is part of the resistance to E.U. membership by the wealthy in England. It's all too easy to avoid U.K. taxes by retiring to Spain, Italy, or Greece. If the U.K. joins the E.U. this scheme is spoiled. There's other places to live, but far fewer people willing to live out their life on the island of Jersey. .