Expatriation Tax Services

What You Will Learn

• 1 Learn the definition of covered expatriate under Section 877A and the historical evolution of the exit tax.
• 2 Understand the covered expatriate determination process including net worth, tax liability, and compliance tests.
• 3 Apply the mark-to-market exit tax computation using hypothetical gain methodology and exclusion amounts.
• 4 Analyze exceptions for dual citizens, minors, and individuals who expatriate for non-tax reasons.
• 5 Implement Form 8854 filing requirements, including certification and information reporting deadlines.
• 6 Evaluate the tax consequences of expatriation on deferred compensation items and non-qualified plans.
• 7 Assess the impact on trust distributions, including grantor and non-grantor trust interests.
• 8 Plan for pre-expatriation restructuring to minimize exit tax liability through recognized loss harvesting.
• 9 Comply with post-expatriation reporting obligations such as FBAR, FATCA, and PFIC rules.
• 10 Develop a comprehensive compliance framework covering penalties, reasonable cause relief, and professional engagement.