Written by attorney Matthew Adam Pek

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 (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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