The United States has tax treaties with nearly 70 countries to prevent double taxation and curb tax evasion. These treaties, based on Article II, Section 2 of the U.S. Constitution, are reciprocal and...
Real estate activities are highly regulated, and each state has laws governing specific prohibited practices as well as liabilities and penalties for violations. Explore this state law survey covering...
Contractual disputes regarding allegations of fraud are often complex, time-consuming, and expensive to litigate. Parties may amicably negotiate an acquisition agreement without even considering whether...
This practice note covers FDA prior notice requirements for imported food, including scope and exceptions, notification contents and timing, methods of submitting notice, and consequences for failing to...
Do you need guidance on drafting international employment contracts? Read our International Employment Agreements: Key Drafting Tips practice note, by John L. Sander, Michael Watts, and William Ellis,...
With multiple European and South American countries promising an affordable retirement, Americans are increasingly renouncing U.S. citizenship and expatriating, some gaining citizenship, outside the United States. Relinquishing U.S. citizenship (or green card status) means not being taxed on worldwide income. IRC Sections 877 and 877A impose an expatriation tax on certain U.S. citizens who relinquish their U.S. citizenship and on certain long-term U.S. residents who terminate their residencies in the United States. Unlike some other areas of federal taxation, the IRC subjects these “covered expatriates” to federal tax on the net unrealized gain inherent in their properties—despite the absence of any recognition transactions. In general, the expatriation tax aims to prevent tax avoidance by those who otherwise would take the taxing opportunity with them. Bon voyage!
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