Green Card Holders and #Americansabroad: “Residence”, “Long Term Residence” and the S. 877A “Exit Tax”

FATCA & CRS Training. Advice. Consultancy.

Introduction (my own, not the author of the post, John Richardson).

Phil Hodgen’s Expatriation Letter of the Week is based upon this concept: whether tax liability of a green-card holder depends upon residency only or whether it includes other factors to consider in order to protect oneself from the long and complicated arms of IRS regulations. The example is simple and offers no less than 5 possible ways to deal with ending a non long-term status as a permanent resident of the United States. It is astounding that so much can be involved for a residence of 3 months with no income earned (US source or otherwise). Only in the USA could things be this complicated and full of possible issues (audits, penalties, etc).

Someone who is a nonresident will only be required to file a U.S. tax return because of:

  • receiving income from U.S. sources; or
  • being engaged in…

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