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Expatriation

Case Conclusion Date: 09.11.2013

Practice Area: Tax

Outcome: Happy clients.

Description: Dual French-U.S. Citizen worth $250,000,000 divided estate with wife who remains in U.S. Husband expatriated in March, 2013, so that appreciation on his $125,000,000 of the assets is not subject to U.S. income tax and will not be subject to U.S. estate tax on his death. The IRC Section 877A exit tax, which was deferred, was only $15,000,000.

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