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Strategies & Market Trends : 2026 TeoTwawKi ... 2032 Darkest Interregnum -- Ignore unavailable to you. Want to Upgrade?


To: Maurice Winn who wrote (53435)8/11/2009 6:41:30 PM
From: TobagoJack  Read Replies (1) | Respond to of 218043
 
maurice, just in in-tray, as boyz on e-mail blog discuss the situation they wish to decamp from but finding the other side of the "tradeable citizenship coin" dear

On the subject of expatriating from the US, since I exchanged my US passport for Ireland in 1992 I can recite my own tax experience,as well as provide my understanding of tax changes since that time. In brief,I have paid zero income tax since 1992 to the USA. This is because I've owed the US nothing since then. In my era Sec. 872 of the IRS Code (which still exists) was all that mattered. 872 holds that persons who leave the US for tax reasons (defined as anyone exchanging their status for a lower tax regime) could be held to an expanded concept of "US tax income", which basically meant that dividends,interest,and capital gains that had a US source were taxed at the same marginal rate as if you never left the country for a period of 10 years. There's one catch. The US Treasury has to notify you in writing that 872 applies within 2 years, otherwise you're just an ordinary foreigner exempt from these punitive provisions. Bureaucracy being what it is I was never notified,which was at odds with all legal advice I'd received.

A major reason I left the US in the early 90s was well-documented advice that it was highly likely the country would introduce a wealth tax on future expatriates. This has happened,so basically I'd be required to mark-to-market my worldwide assets and pay an excise tax on the notional gain over my tax basis if I was attempting to do the same thing in 2009. So a lot depends on the individual,many wealthy people likely have little or no gain over their tax cost on the bulk of their assets,and the brunt of 872 (if asserted by Treasury) can easily be avoided by confining yourself to non-US and overseas derivatives markets.