Newly introduced Exit Tax  
     
  Unfortunately, here is some bad news for US citizenship or Green Card holders who are thinking of giving up their US citizenship or for Green Card holders who are thinking of giving up their Green Cards. You need to consider tax implications of newly introduced Exit Tax on your decision.  
     
  Exit Tax that is imposed on the expatriate’s unrealized gains and accrued income.  
     
  And it is applicable to any U.S. Citizen who relinquishes citizenship and any long-term resident who terminates U.S. residency on or after June 17, 2008 and who :  
     
 
1] Has an annual net income tax liability for the five preceding years before the date of the loss of U.S. Citizenship or residency termination that exceeds $139,000 (for 2008), as adjusted for inflation in future years  
2] Has a net worth of at least $2 million or  
3] Fails to certify that he has complied with all U.S. Federal tax obligations for the preceding five years.  
4] Foreign executives who were permanent residents of U.S. for more than 8 years and then return to their home country.  
     
 
  Thus, persons who renounced their US citizenship or surrendered their Green Cards before June 17, 2008 are outside the purview of the exit tax.  
     
  It is not applicable for the dual citizens from birth and persons who expatriate before the age of 18 years.  
     
 
What is Included?
   
1] All global assets of the expatriate will be treated as sold for FMV and the deemed gain will be taxed.
2] Certain deferred compensation items
3] Interest on certain specified tax deferred accounts
   
 
  How much is taxed?  
     
  All deemed gains realized after $600,000 exemption.  
     
  Conclusion:  
 
   
1] Expatriating can now result in immediate and significant US federal income taxes to an individual with substantial assets
2] An individual who is potentially a covered expatriate should consult his or her US tax adviser before renouncing citizenship or relinquishing a green card.
3] The new transfer tax rules, must also be considered in any estate planning for covered expatriates with US connections.