Expatriation Of U.S. Citizens and GreenCard Holders
For The Last Quarter of 2016.
U.S. citizens who have renounced their citizenship and long-term residents (as defined in IRC 877(e)) who have ended their U.S. resident status for federal tax purposes.
Expatriation on or after June 17, 2008
If you expatriated on or after June 17, 2008, the new IRC 877A expatriation rules apply to you if any of the following statements apply.
• Your average annual net income tax for the 5 years ending before the date of expatriation or termination of residency is more than a specified amount that is adjusted for inflation ($151,000 for 2012, $155,000 for 2013, $157,000 for 2014, and $160,000 for 2015).
• Your net worth is $2 million or more on the date of your expatriation or termination of residency.
• You fail to certify on Form 8854 that you have complied with all U.S. federal tax obligations for the 5 years preceding the date of your expatriation or termination of residency.
If any of these rules apply, you are a “covered expatriate.”
A citizen will be treated as relinquishing his or her U.S. citizenship on the earliest of four possible dates:
1. the date the individual renounces his or her U.S. nationality before a diplomatic or consular officer of the United States, provided the renunciation is subsequently approved by the issuance to the individual of a certificate of loss of nationality by the U.S. Department of State;
2. the date the individual furnishes to the U.S. Department of State a signed statement of voluntary relinquishment of U.S. nationality;
3. the date the U.S. Department of State issues to the individual a certificate of loss of nationality; or
4. the date a U.S. court cancels a naturalized citizen’s certificate of naturalization.
For long-term residents, a long-term resident ceases to be a lawful permanent resident if:
A. the individual’s status of having been lawfully accorded the privilege of residing permanently in the United States as an immigrant in accordance with immigration laws has been revoked or has been administratively or judicially determined to have been abandoned, or
B. the individual:
1. commences to be treated as a resident of a foreign country under the provisions of a tax treaty between the United States and the foreign country,
2. does not waive the benefits of the treaty applicable to residents of the foreign country, and
3. notifies the IRS of such treatment.
Click Here for the last quarter of 2016 listing of individuals who chose to relinquish their U.S. Citizenship or Green Card Status with the United States.