|
|
Article: Expatriation and the new mark-to-market rules.
- Article from:
- The Tax Adviser
- Article date:
- July 1, 2009
- Author:
CopyrightCOPYRIGHT 2009 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
|
EXECUTIVE SUMMARY
* Under Sec. 877A, expatriating citizens and long-term residents of the United States are taxed on the gains of a deemed sale (on the day before the expatriation takes place) of their worldwide assets in excess of $600,000. This mark-to-market tax replaces the 10-year alternative tax on U.S. source income under Sec. 877.
* Taxpayers may make an irrevocable election to defer the tax due on the deemed sale of specific assets under the mark-to-market rules until the due date of the tax return for the year in which the asset is sold and a realized gain occurs. Exceptions to the tax are provided for certain deferred tax items, specified ...