International Assignments: US – IRS issues guidance on new exit tax

30 January 2012 |

The US Internal Revenue Services (IRS) has issued guidance on the new exit tax that applies to individuals subject to US expatriation on or after 17 June 2008.

Expatriation is a term used to refer to individuals who have given up their US citizenship and long term residents who cease to be a permanent resident of the US.  There are two parts to expatriation:

  • firstly, there are the legal aspects of giving up citizenship; and
  • secondly, the individual will need to file the required forms with the IRS which satisfy its requirements.

It is expected that future regulations incorporating this new guidance will apply to individuals expatriating on or after 15 October 2009.  Until these regulations are issued, such individuals may rely on this IRS guidance.  In addition, individuals whose expatriation date is on or after 17 June 2008, and before 15 October 2009, may also rely on the new guidance.

Resources

Link to IRS

For further information, please contact Bina Gayadien (bina.gayadien@abbisscadres.com) or Guy Abbiss (guy.abbiss@abbisscadres.com) on +44 (0) 203 051 5711.

Disclaimer

Content is for general information purposes only.  The information provided is
not intended to be comprehensive and it does not constitute or contain
legal or other advice.  If you require assistance in relation to any
issue, please seek specific advice relevant to your particular
circumstances.

Disclaimer

Content is for general information purposes only. The information provided is not intended to be comprehensive and it does not constitute or contain legal or other advice. If you require assistance in relation to any issue please seek specific advice relevant to your particular circumstances. In particular, no responsibility shall be accepted by the authors or by Abbiss Cadres LLP for any losses occasioned by reliance on any content appearing on or accessible from this article. For further legal information click here.

Circular 230 disclosure

To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this article (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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