The Exit Tax

It has been more than three years since the enactment of Sec. 877A, which introduced a mark-to-market tax on U.S. persons expatriating on or after June 16, 2008. Its introduction has impacted the decisions of many to attain a green card or citizenship. It can be costly for wealthy individuals to become a covered expatriate (as described below) and, consequently, taking steps to avoid becoming a covered expatriate has become a fundamental part of pre-immigration planning.