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TAXPATRIATION and The Reed Amendment - Why expatriating for tax shelter purposes may be a bad idea.

Additional resources provided by the author

Federal Information Systems Corporation, Transcript 952970478, Hearing of the House Judiciary Committee, Subject: Mark-Up of Immigration Legislation (October 24, 1995).

See, e.g., Michael G. Pfeifer, Expatriation: The Ultimate Estate Planning Tool?, SK024 ALI-ABA 551, 581 (2004).

See STAFF OF JOINT COMM. ON TAXATION, 108TH CONG., 1ST SESS., REVIEW OF THE PRESENT--LAW TAX AND IMMIGRATION TREATMENT OF RELINQUISHMENT OF CITIZENSHIP AND TERMINATION OF LONG-TERM RESIDENCY (Comm. Print 2003), available at http://www.house.gov/jct/s-2-03.pdf (last visited Feb. 20, 2007) (hereinafter “2003 JCT Report”) at 72.

See 2003 JCT Report at 100.

See 2003 JCT Report at 101 (“[w]ithout agreement on the individuals to whom the law applies, no action can be taken”).

See Elise Tang, Solving Taxpatriation: “Realizing” It Takes More Than Amending the Alternative Tax, 31 Brook.J.Int’l L. 615, 628 (2006) (citing Michelle Leigh Carter, Note, Giving Taxpatriates the Boot Permanently?: The Reed Amendment Unconstitutionally Infringes on the Fundamental Right to Expatriate, 36 Ga.L.Rev. 835, 839 (2002)); see also 2003 JCT Report at 100.

See G. Warren Whitaker, U.S. Tax Planning for Non-U.S. Persons and Trusts: An Introductory Outline, 325 PLI/Est 1015, 1046 (2003); see also Pfeifer, supra, at 582.

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