Playing Chess vs. Checkers: The pitfalls of renouncing one’s citizenship

by: Michael Reps

I read with interest your recent articles on renouncing ones US Citizenship. I would like to share my observations on this topic as I assist businesses in emigrating from the US to New Zealand and the topic of renunciation of one’s citizenship surfaces on many occasions.

The enormity of renouncing one’s citizenship should not be taken lightly. It is my experience that a hasty divorce may lead to a new partnership that’s even less desirable then the previous. Foremost in your consideration to renounce should be the sovereign powers of the new country you plan to call home.

Does that new country have a double taxation treaty with the US? Does the US have jurisdiction for enforcement for claims against tax liabilities?

Whenever I read laws and regulations that appear broad based and generalized in nature I immediately become suspicious and concerned. It is through this vagueness that I believe the courts allow for themselves latitude and room to maneuver around what on the surface appears clear, but when it comes to your day in court, and under the atmosphere of what I believe are going to be increased efforts for the prevention of capital flight from the US, I become concerned.

There are 3 words in the IRS Codes language regarding taxation under renunciation of citizenship that everyone should consider. “For Tax Purposes.” It is this language that I believe many will have to navigate through in order to satisfy themselves as well as the courts of any future redress of income and penalties owed back to the US.

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