New Regime Is Onerous to Expatriates

On June 17, 2008 President Bush signed new expatriation legislation unanimously passed by Congress as part of the Heroes Earnings Assistance and Relief Tax Act of 2008 (H.R. 6081) (the "Heroes Act"). There are three particularly significant new aspects of the expatriation provisions of the Heroes Act, which are summarized below.

"Mark-to-Market" Tax The Heroes Act dramatically changes the current income tax regime applicable to certain U.S. citizens who expatriate and certain long-term U.S. residents (e.g., ...

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