A First Impression of the Expatriation “Inheritance Tax”

A First Impression of the Expatriation “Inheritance Tax”

Tax Law
By Anthony Diosdi A record number of individuals have expatriated from the United States in 2020. For federal tax purposes, expatriation means 1) any United States citizen who relinquishes his or her citizenship or 2) any long-term resident of the United States who ceases to be a lawful permanent resident of the United States. The abandonment of citizenship or long-term residence may result in the assessment of the expatriation tax. This tax consists of the “exit tax” and the inheritance tax. This article will focus on the inheritance tax. An Overview of the Exit TaxThe Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART Act”) added Section 877A to the Internal Revenue Code. This code section imposes an exit tax on individuals who expatriate on or after June 17,…
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