10Aug 2022 by Pat Geddie
RSUs and the Expatriation Tax

RSUs and the Expatriation Tax

Tax Law
By Anthony Diosdi A restricted stock unit (“RSU”) is a form of stock based compensation used to reward employees. Restricted stock units vests at some point in the future. Unlike stock options, RSUs have some value upon vesting. That is, unless the underlying stock becomes worthless. An RSU is a grant whose worth is based on the value of the company issuing the stock. Until a grant of RSUs vest, there is no U.S. tax consequence. In other words, until an RSU vests, it is nothing more than an unfunded promise to issue a share to the holder of the grant until some point in the future. The U.S. Tax Consequence of the Vesting of an RSUOnce an RSU vests, the recipient is taxed on the value of the shares…
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04Mar 2021 by Pat Geddie
How a Treaty-Tie Breaker Provision May Save Departing Long-Term Green Card Holders from the Expatriation Tax

How a Treaty-Tie Breaker Provision May Save Departing Long-Term Green Card Holders from the Expatriation Tax

Tax Law
By Anthony Diosdi A record number of individuals have expatriated from the United States in 2020. Much of this expatriation is from citizens of other countries who were issued green cards. People from around the world are attracted to the United States because of lucrative employment or business opportunities. However, a significant number of these individuals decide to either return to their home countries or seek opportunities elsewhere. The U.S. tax system (which taxes U.S. residents on their worldwide income) makes holding on to a green card too expensive to keep and many decide to relinquish it. To the surprise of many, the relinquishment of a green card can trigger a very expensive expatriation tax. This article will explain the mechanics of the expatriation tax. This article also discusses how…
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