Contents1 Deferred Compensation Non-U.S. Person & Expatriation2 Notice 2009-85 – Services Performed Outside the United States3 […]
Contents1 Expatriation Notice 2009-85: Section 4 (Other Provisions)2 Termination of Deferrals3 IRC 367 (a) Gain Recognition […]
Mark-to-Market (Category 3) Notice 2009-85 Mark-to-Market & IRS Notice 2009-85: When U.S. Persons are considering expatriation, […]
Contents1 IRS Notice 2009-85 (Section 2: Individuals Covered)2 Who is Considered Expatriate?3 Interested in Expatriation from […]
Contents1 Notice 2009-85 (Section 1)2 IRS Notice vs. Revenue Procedure3 Notice 2009-85 (Section 1) Overview4 Interested […]
Contents1 Covered Expatriates & Nongrantor Trusts 2 What is a Non-Grantor Trust?3 Non-Grantor Trust Expatriation Exit Tax […]
Contents1 Step-up Basis at Expatriation for Foreign Assets2 Expatriation & Step-Up Basis3 Example of Step-Up Basis […]
Contents1 Accidental Americans, Expatriation & Renunciation2 Steps Accidental Americans Should Take3 A Few Expatriation Tips4 Interested […]
Contents1 Tax Planning for Expatriation Before Immigration2 Permanent Resident or Visa Holder?3 Expatriation & Exit Tax […]
Contents1 Wealth Transfers & Expatriation2 Expatriating Spouse Wealth Transfer3 U.S. Citizen Non-Expatriating Spouse4 Non-U.S. Citizen Non-Expatriating […]