Expatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World

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1 Expatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World Henry Christensen III Jay E. Rivlin Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los Angeles Miami Milan Munich New York Orange County Paris Rome Seoul Silicon Valley Washington, D.C. Strategic alliance with MWE China Law Offices (Shanghai) 2013 McDermott Will & Emery. The following legal entities are collectively referred to as "McDermott Will & Emery," "McDermott" or "the Firm": McDermott Will & Emery LLP, McDermott Will & Emery AARPI, McDermott Will & Emery Belgium LLP, McDermott Will & Emery Rechtsanwälte Steuerberater LLP, McDermott Will & Emery Studio Legale Associato and McDermott Will & Emery UK LLP. These entities coordinate their activities through service agreements. This communication may be considered attorney advertising. Previous results are not a guarantee of future outcome.

2 U.S. Perspective What Does It Mean to Expatriate? To expatriate is to irrevocably relinquish U.S. citizenship, with all of its attendant obligations and privileges. At the time of expatriation, a potential expatriate must be a citizen of at least one other country, so that he/she is not rendered stateless by the act of relinquishing U.S. citizenship. Unlike all European countries, and unlike almost all countries (a few, like the Philippines, follow the U.S. model), the U.S. subjects its citizens to income tax on their worldwide income, and to estate tax on their worldwide estate, wherever they live. So, citizenship means more as a tax matter to a U.S. citizen than it does to a U.K. subject. 2

3 U.S. Perspective Overview of Expatriation Tax Regime The U.S. imposes a mark-to-market exit tax on certain citizens who expatriate, as well as on certain green card holders. The exit tax applies to individuals who meet the definition of a covered expatriate ( CE ). The U.S. also imposes a succession tax on U.S. citizens or residents who receive a covered gift or bequest from a CE, even years after expatriation. A direct or indirect distribution from a nongrantor trust to a CE who was a beneficiary of that trust at the time of the CE s expatriation will be subject to a 30% withholding tax (unless the CE elects to include the value of his/her interest in the trust in his/her exit tax base). Special rules apply to the taxation of a CE s deferred compensation assets (for example, IRAs, 401(k)s, qualified and nonqualified pension plans). An expatriate may spend significant time in the U.S. without becoming taxable as a U.S. person as long as the expatriate does not become substantially present in the U.S. 3

4 Long-Term Residents As mentioned on the previous slide, the mark-to-market exit tax is also applicable to certain green card holders who satisfy the definition of a long-term resident under I.R.C. 877A(g)(5) and 877(e)(2) and who qualify as a CE. A long-term resident is any individual (other than a U.S. citizen) who is a lawful permanent resident of the U.S. in at least 8 of the last 15 years. An individual is not considered a lawful permanent resident for any year in which such individual is treated as a resident of a foreign country under a tax treaty between the U.S. and that foreign country (and such individual does not waive the benefits of such treaty). I.R.C. 877(e)(2). 4

5 Who Is a Covered Expatriate? An expatriate will be a covered expatriate if he/she meets: An income tax liability test (an average annual net U.S. income tax of $155,000 for the five years preceding expatriation); or A net worth test (a net worth of $2,000,000 or more); or Either: (i) fails to certify under penalties of perjury on IRS Form 8854 that he/she has been in compliance with all U.S. federal tax laws for the five years preceding expatriation; or (ii) fails to submit evidence of such compliance as the Secretary of the U.S. Treasury may require. It is possible to arrange one s financial affairs in order to avoid being classified as a CE at the time of expatriation. The income tax liability test amount is adjusted for inflation, but the net worth test amount is not. 5

6 Exceptions to Covered Expatriate Status A child will not be a CE if the child expatriates prior to age 18½ (i) having never been a U.S. resident, or (ii) having been a resident of the U.S. for not more than 10 taxable years before the date of relinquishment. Special Exception for Dual Nationals from Birth. An individual may expatriate at any time subsequent to attaining age 18, and the individual will not be a covered expatriate, if the following conditions apply: 1) the individual became at birth a U.S. citizen and a citizen of another country; 2) as of the expatriation date, continues to be a citizen of, and is taxed as a resident of, such other country; and 3) (i) has never been a resident of the U.S.; or (ii) has been a resident of the U.S. for not more than 10 taxable years during the last 15-taxable year period ending with the taxable year during which the expatriation date occurs. Residence in the U.S. is determined under the substantial presence test of I.R.C. 7701(b)(i)(A)(ii). This is a mechanical, day-counting test. 6

7 Imposition of Mark-to-Market Exit Tax A CE is exposed to U.S. federal income tax liability in the form of an immediate exit tax whereby the CE s personal worldwide property is deemed sold and tax is paid on the resulting notional gain in excess of $668,000 (the inflation-adjusted amount for 2013) at the applicable capital gains rate. So, only a CE who has more than $668,000 of net appreciation in his/her worldwide property will have an exit tax liability; conversely, CEs who are in a net loss position will not be liable for any exit tax. A CE includes in the CE s exit tax base any interest in property that would have been taxable as part of his/her gross estate for U.S. federal estate tax purposes had the CE died a U.S. citizen on the day before expatriating. Generally, this is the taxpayer s worldwide property, but certain trust interests and items of deferred compensation are treated differently. 7

8 Imposition of Mark-to-Market Exit Tax A CE must obtain fair market value appraisals of his/her worldwide property and attach the appraisals to the CE s final U.S. income tax return. An appraisal is only required for assets for which a ready market value is not available (for example, real estate or closely-held assets). Quoted market prices on the day prior to expatriation will suffice for marketable securities. A taxpayer may elect to defer the exit tax payable with respect to a particular asset, provided that security for the ultimate payment of the tax is posted and interest is paid over the deferral period. A CE must file a detailed Expatriation Information Statement on IRS Form 8854 with the CE s final year U.S. federal income tax return, certifying under penalties of perjury that the CE has been in compliance with all U.S. federal tax laws for the five years preceding the date of expatriation. 8

9 U.S. Perspective Inheriting from a Covered Expatriate A U.S. citizen or resident who receives a covered gift or bequest from a CE will be subject to a succession tax on that gift or bequest at the highest applicable rate of gift or estate tax. I.R.C Not all gifts or bequests from a CE are covered gifts and bequests. For example, succession tax is not imposed on annual exclusion gifts or on gifts or bequests to a U.S. spouse or charity. Also, the term does not include: (i) property reported on a timely filed gift tax return that is a taxable gift by the CE, or (ii) property included in the gross estate of the CE and reported on the CE s timely filed estate tax return. For example: - If a CE made a gift or bequest of U.S. real estate to his/her U.S. citizen child, that gift or bequest would be reportable on a gift or estate tax return and would be subject to U.S. gift or estate tax, but would not be subject to the succession tax in the hands of the U.S. citizen child. - However, a CE s bequest to a U.S. citizen child of a portfolio of non-u.s. securities would be subject to the succession tax, because that property would not be subject to U.S. estate tax. Receipt of a covered gift or bequest by a domestic trust is treated no differently than if an individual had received it, but the trustee must pay the tax from the trust. The transfer tax applies to all covered gifts or bequests, even if the property gifted or bequeathed was acquired by the CE long after he or she expatriated. 9

10 U.S. Perspective Transfer Tax Rules Applicable to Nonresident Aliens After expatriating, the expat would be a nonresident alien for U.S. estate, gift and GST tax purposes, and could arrange his/her affairs so as to minimize U.S. transfer or succession taxes in the event of a gift or bequest. The expatriate s ability to transfer assets at his/her death without exposure to U.S. tax would depend on many factors, including the citizenship of his/her children and the nature of his/her assets. As a general matter, a nonresident alien is subject to U.S. gift tax on gifts of U.S. real estate and tangible property situated in the United States. Cash in a U.S. bank account is considered tangible property for gift tax purposes. As a general matter, a nonresident alien is subject to U.S. estate tax on bequests of U.S. real estate and tangible property situated in the United States. Cash in a U.S. bank account is considered intangible property for estate tax purposes. In addition, stock in domestic corporations also is subject to estate tax if owned by a nonresident alien at his/her death, but is not subject to gift tax. A nonresident alien may undertake special planning to reduce U.S. estate tax exposure. Even if that planning successfully eliminates exposure to the estate tax, if those assets pass at the CE s death to a U.S. citizen or resident children (or trusts for their benefit) then the succession tax will apply. 10

11 Issues to Consider Before expatriating, the following tax issues should be addressed: Impact on beneficial interests in trusts (existing and future trusts) Implications for estate planning for the expatriate s spouse and descendants Impact on personal net worth and employee benefits Timing of events Application of one or more treaties to income, estate and inheritance tax analysis Before expatriating, the following non-tax issues should be addressed: Comfort level with reducing amount of time spent in the U.S. so as not to become a U.S. person for income tax purposes Acquiring citizenship in another country 11

12 Expatriation of Children Sometimes it may not be beneficial for a parent to expatriate, but it may be beneficial for the children of such parent to expatriate. As discussed above, under certain circumstances, a child who expatriates before age 18½ or a child who has been a dual national from birth may expatriate without ever being classified as a CE. Therefore, such child escapes the expatriation tax regime. Regardless whether a child qualifies for one of the exceptions, any child for whom expatriation is beneficial should do so prior to the death of the parent. Otherwise, trusts created for the benefit of the child by such parent become irrevocable and could result in future distributions to such child being subject to tax that would not otherwise be imposed had the child expatriated prior to the parent s death. 12

13 Alternative to Expatriation for Certain Long Term Residents For certain long-term residents, there may be an alternative to expatriation that results in similar or better tax treatment. A long-term resident may find that the results of expatriating are not significantly different than obtaining U.S. citizenship, returning to such individual s home country, and then claiming protection from various taxes afforded by any tax treaties between the U.S. and the individual s home country. 13

14 Number of U.S. Expatriations Per Year 14

15 Reasons for Expatriation Despite the potential cost of expatriation due to the mark-to-market tax, the number of expatriates has steadily increased since Several factors may explain this result: Preparing Tax Returns - A U.S. citizen living abroad is required to prepare an income tax return even if the U.S. citizen (due to the foreign earned income exclusion or the foreign tax credit) does not ultimately pay any income tax. These foreign-resident U.S. citizens have additional forms to file as compared to U.S. residents, which may render tax return preparation expensive and burdensome. For U.S. citizens who have never lived in the U.S. (i.e. born abroad to U.S.-citizen parents), and who do not expect to live in the U.S. in the future, retaining U.S. citizenship may not be worth this burden. Penalties - For U.S. taxpayers with foreign financial assets with an aggregate value exceeding $50,000, there is a penalty for failing to report such foreign financial accounts. Banking - Foreign financial institutions may choose to shed their U.S.-citizen clients, or refuse to open new accounts for U.S. citizens, to avoid the risks, burdens and costs associated with complying with the Foreign Account Tax Compliance Act s (FATCA s) requirements. For U.S. citizens residing abroad, this may render banking more difficult. Estate Tax - Estates of U.S. citizens living in countries that impose little or no estate tax may be profoundly impacted by the U.S.-imposed estate tax. For example, upon the death of a U.S. citizen who resides in a country with no estate tax and who owns a business, a U.S. estate tax will be imposed upon such citizen s share of the business. Thus, expatriating before death and before an increase in the value of one s business may be an attractive option. 15

16 Reasons to Retain U.S. Citizenship Although there is no reliable statistical information on U.S. citizens who consider expatriating and ultimately do not, there are several factors that may encourage those considering expatriation to retain U.S. citizenship, including: A desire to reside in the U.S. in the future International sanctions imposed on citizens of certain other countries General ease of travel for U.S. citizens Retention of U.S. citizenship so that one s children are born U.S. citizens 16

17 Circular 230 Notice To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter herein. 17

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