Expatriating Taxpayers and Unfiled Form 8854: Administration Proposes Disparate Treatment Based on Financial Status


 

Certain U.S. individuals who cease their relationship with the United States must pay an “exit tax.” One major problem is that some taxpayers intentionally fail to file Form 8854 (Initial and Annual Expatriation Statement) to notify the IRS of their departure, keep a low profile for a few years, and thus dodge the exit tax. Other taxpayers, particularly so-called accidental Americans, do not maintain U.S. tax compliance or properly expatriate for less nefarious reasons. The current Presidential Administration has suggested changes for both categories of taxpayers. This article analyzes the exit tax, an IRS relief program for individuals who incorrectly expatriated in the past, and pending proposals.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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