US Exit Tax Wrapup in Forbes
The current Forbes has a good short article wrapping up the status of the "taxpatriate" control movement in Congress. The Health Care Bill that passed in August didn't include an Exit Tax as previously reported. What it did contain was a provision that states that taxpatriates with a net worth of more than $500K who renounce their citizenship will still be on the hook for ten years for income taxes on their US source income. This provision is easily dodged however by tax planning techniques that assure that the individual involved has no US source income. Borrowing and trusts can be substituted for an income stream. The second provision was in the immigration bill. It subjects all those who renounce their US citizenship (for any reason) to a visa requirement for entry to the US. State can then deny visas in cases where the expat is a taxpat. This applies to new citizens of those OECD countries that have visa-free entry to the US. How State will filter recent expats out of the flow for special treatment is unclear, however. Nation of birth is shown on passports, so that might be able to be used. This gimmick is also easily dodged by entry into Canada or Mexico with a low profile border crossing into the US. Gee, I wish I had enough assets to become a taxpatriate. DCF "Vote for the only Swiss Citizen in the Presidential race -- Harry Browne."
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Duncan Frissell