QUESTION: In your latest newsletter, you included link to IRS site on
expatriation, which left me with following questions:
1.) I understand that there now is an exit tax. Is this only applicable to
those with ">$2mil net worth or avg income tax liability of $127,000 for the 5
prior years"?

REPLY: Yes - for those who expatriated after June 17, 2008. But for 2008, the
average tax liability is $139,000 and you must certify on Form 8854 that you
have met all of your tax obligations for the past five years.

QUESTION: Or in other words, if I expatriate and have net worth <$2mil and tax
liability <$127k, then am I exempt from exit tax?

REPLY: Same answer as above.

QUESTION: What is exit tax amount or percent? This is missing from document on
IRS website.

REPLY: The gain or loss in excess of $600,000 is reported the same as if the
property had been sold. Although not stated in the instructions, this would
require the preparation of an income tax return and I presume it would include
any other taxable income for the year of expatriation.

QUESTION: Previously, I understand that those expatriating with >$2mil net worth
or >$127k annual income tax were subject to tax for additional 10 years. Is this
still applicable?

REPLY: Yes -- for those who expatriated before June 17, 2008

QUESTION: I.e. Does one now pay exit tax and still pay tax for 10 years to USA
on retained wealth?

REPLY: No

Vern

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