Tag: IRC Sec 877A(b)

  • Relinquishing Permanent Residency or U.S. Citizenship

    The expatriation rules apply to U.S. citizens or long term residents that have a Green Card in eight of the last fifteen years preceding the application for expatriation. The expatriation rules are applicable if the taxpayer meets one of two test. A “covered expatriate” is a taxpayer that meets the Net Worth Test of IRC…