
For multinational families, advanced planning teams look for global solutions.
Let's say you have long-time clients - a Boston-area couple in their early 60s - who plan to retire soon from their respective Fortune 100 executive positions and spend most of their time overseas at their second home in the south of France. They also want to be closer to their children: a son living in Madrid who is married to a citizen of Spain and a grown daughter now residing in London.
Giving up your U.S. passport will now come at a very high price. A new law signed by President Bush on June 17, 2008 (H.R. 6081) will subject certain people who decide to expatriate or turn in their green cards to an immediate exit tax.
None of us is immune to the challenge of trying to understand the ever-changing tax picture that confronts U.S. Citizens living, working and investing domestically. The nuances and burdens of Alternative Minimum Tax, evolving State tax laws and the estate tax landscape in flux are all but examples of this phenomenon. U.S. expatriates, however, remain subject to all such basic rules while abroad (based upon the principle of taxability founded on U.S. Citizenship), but are also impacted by rules specific to their status as expatriates, in addition to being subject to foreign tax laws. In this way, an already complex tax profile can become thoroughly confusing! Understanding the interaction of these various tax rules, however, is critical to managing tax exposure and to avoiding double taxation.