Guidance on New U.S. Exit Tax Provisions Expected Soon
Tax Analysts
January 13, 2009
International & Cross Border Transactions attorney Summer LePree served as a panelist at the American Bar Association Section of Taxation meeting. The panel discussed sections 877A and 2801 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (P.L. 110-245). Tax Analysts published a summary of the meeting and cited Ms. LePree's presentation on the new mark-to-market rules and noted issues related to section 877A, which replaced the former 10-year alternative tax regime on U.S.-source income of covered expatriates with a mark-to-market tax on gains in excess of $600,000 from a deemed sale of an individual's worldwide assets on the day before the individual's expatriation date.
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