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Tag Archive for Form 8854

U.S. Expatriation – Tax Information When Renouncing

Larry Stolberg

Renunciation of U.S. citizenship is an expatriation event requiring the filing of IRS Form 8854 with your tax return for year of expatriation. Renunciation has a fee of US $2,350.

Renunciation is voluntary and requires an appointment for receiving a certificate of loss of nationality.

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The Internal Revenue Code Versus The IRS Form: Noncovered Expatriate Status And Form 8854

John Richardson

 For Whom The IRS Form Tolls

I would not want the job that the IRS has to create forms given there are many “information reporting requirements” in the Internal Revenue Code. The IRS has the job (sometimes mandatory “shall” and sometimes permissive “may”) of having to create forms that reflect the intent of the Internal Revenue Code. The forms will not necessarily reflect how the IRS interprets the text and intent of the Code. Once created, the “forms” become a practical substitute for the Code. If you look through your tax return you will find “form” after “form” after “form” how the various provisions of the Internal Revenue Code are “given meaning” (if the meaning can be determined).

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Canada Pension Plan (And Other “Foreign Social Security”), The “Net Worth” Test, Form 8854 And Form 8938

John Richardson

Q. How does the inability of the state of Rhode Island to pay its employee pensions help us understand the “net worth” of a U.S. citizen wanting to renounce U.S. citizenship?

A. The answer (like most wisdom in the modern world) is explained in the following tweet.

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What Offshore Delinquent U.S. Individual Filers Need To Know! – Part 2

Does giving up U.S. citizenship or my green card get me out of my U.S. filing obligations?

Answer

Absolutely not.

Those who wish to wish to explore expatriation by giving up U.S. citizenship or their green card will have to timely file IRS Form 8854 and compute if applicable, an exit type tax if they are considered a “Covered Expatriate” (“CE”) under Section 877A of the IRS Code.

The exit tax is composed of a market to market tax on certain unrealized gains in excess of $668,000 (2013) and a 30% tax on future receipt of certain deferred items. The market to market tax may be deferred if you meet certain conditions. Read more