The Tax Rules Just Changed: Emotions Aside, Does Expatriating Make Financial Sense?
Kevin E. Packman is a senior associate with Holland & Knight. His practice focuses on estate and gift tax planning for domestic and international clients as well as on pre-immigration planning for international clients. Mr. Packman's article discusses the Heroes Earnings Assistance and Relief Tax Act of 2008 (the "HEART Legislation") that was signed by President Bush on June 17, 2008. Buried in the Heart Legislation was a provision dealing with expatriation, which imposes an exit tax on persons leaving the US, and a gift or estate tax on US recipients of property from an expatriate. This article discusses the new provisions and contrasts them with the prior legislation.