• Expatriation, Form 8854, Invalidation of IRS Notice, and Next Steps

  • Aug 21 2024
  • Length: 35 mins
  • Podcast

Expatriation, Form 8854, Invalidation of IRS Notice, and Next Steps

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  • Summary

  • Many taxpayers parting ways with the United States must file Form 8854 (Initial and Annual Expatriation Statement). Failure to do so is problematic because it can expose taxpayers to the notorious “exit tax.” Few people have seemed to notice, but significant changes might be on the way. This article analyzes worldwide obligations of U.S. individual taxpayers, exit taxes, foundations for Form 8854 filing duties, legislative proposals for increased enforcement, a recent case invalidating the IRS document that introduced Form 8854, and IRS actions in other contexts where the courts have shot down administrative guidance.
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