Renouncing US Citizenship: Two Solitudes - Separating Immigration/Nationality From Tax

<p>November 29, 2021 - Participants Include:</p> <p><a href='http://www.us-tax.org'>Virginia La Torre Jeker</a> - <a href='http://www.twitter.com/vljeker'>@VLJeker</a></p> <p><a href='http://www.citizenshipsolutions.ca'>John Richardson</a> - <a href='http://www.twitter.com/expatriationlaw'>@Expatriationlaw</a></p> <p> </p> <p>Two Solitudes = U.S. State Department and U.S. Treasury</p> <p>Virginia and I continue our podcasts in which we clarify myths and misconceptions about renouncing US citizenship. This podcast emphasizes the difference between the immigration/nationality aspects of renunciation vs. the tax aspects of renunciation.</p> <p>Although tax compliance is NOT required to renounce US citizenship, renunciation without tax compliance does have tax consequences.</p> <p>This podcast focuses on more areas of misunderstanding and confusion ...</p> <p>Renouncing US citizenship triggers issues under each of:</p> <p>1. The Immigration and Nationality Act under 349(a); and</p> <p>2. The Internal Revenue Code under sections under 7701(a)(50), 877A and 877, 2801</p> <p>To put it simply: There are a lot of moving parts.</p> <p>In this podcast Virginia La Torre Jeker and John Richardson continue our discussion including:</p> <p>Immigration/Nationality Issues:</p> <p>- is tax compliance required to be allowed to renounce US citizenship?</p> <p>- what are the legal requirements to renounce US citizenship?</p> <p>- is a second citizenship required in order to renounce?</p> <p>Tax Issues:</p> <p>- what is a covered expatriate?</p> <p>- what does it mean to be subject to the US 877A expatriation tax?</p> <p>- how are different kinds of assets treated for the purposes of expatriation?</p> <p>- pensions vs. property ...</p> <p>- ways of avoiding covered expatriate status (gifts, pre-renunciation sales, etc.)</p> <p>- what about post-renunciation gifts from covered expatriates to US citizens?</p> <p>- <a href='http://citizenshipsolutions.ca/tag/relief-procedures-for-certain-former-citizens/'>Relief P