News 19 Dec. 2019
Curtis Wins in London for Federal Airports Authority of Nigeria
News 18 Apr. 2016
Curtis gains recognition in new Africa publication
News 26 Feb. 2020
Curtis Secures Comprehensive Victory for the Republic of Kazakhstan’s Committee of Roads
News 24 Jan. 2020
Curtis defeats $400 million investment treaty claim brought against India
Client Alert 07 Apr. 2020
Italy Insight: Care Decree Against COVID-19 (Coronavirus): a Company-Oriented Analysis
Client Alert 03 Apr. 2020
EU Insight: COVID-19 (Coronavirus) – Regulatory Measures and Announcements
Client Alert 26 Mar. 2020
Mexico Insight: COVID-19 (Coronavirus) Legal Implications
News 18 Dec. 2019
Six Curtis Partners Featured in Who's Who Legal - Arbitration 2020
Event 31 Jan. 2020
Partner Antonia Birt Speaks at 5th Annual GAR Live Abu Dhabi
Publications 15 Jan. 2020
Antonia Birt publishes IBA Arbitration Country Guide for the UAE
U.S. Insight: CARES Act Provisions for Small Businesses and Individuals
Client Alert 27 Mar. 2020
U.S. Insight: Data Security and Protection in the New Work-From-Home Regime During Coronavirus/COVID-19
Client Alert 08 Apr. 2020
Mexico Insight: COVID-19 (Coronavirus) / Technical Guidelines Relating to the Activities Outlined in the Health Secretary’s Decree of 31 March 2020
Publications June 2008
Exit Tax on U.S. Expatriates
On June 6, 2008 Congress sent legislation to President Bush which will impose an exit tax on certain individuals who expatriate or give up their green card ('covered expatriates' as defined below). The new legislation would generally treat a covered expatriate as having sold his or her global property at its fair market value on the day before expatriation and require that the tax on such deemed sale be paid on any gain from such deemed sale promptly, unless the covered expatriate makes an election to defer the tax on the gain until such property is disposed and posts security for the amount of any liability not paid promptly. In addition, U.S. citizens or residents who receive gifts or bequests from a covered expatriate will be subject to U.S. gift or estate tax on the property they receive. The legislation becomes effective when the President signs the bill, an event that is expected to occur during the week of June 16.
Under current tax law, a U.S. citizen who expatriates and a long-term resident (i.e., green card holder) who terminates his or her status as a long-term resident (together 'expatriates') is, subject to certain requirements and exceptions, required to report and pay tax on U.S. source income for ten taxable years following his or her expatriation or relinquishment of his or her status as a long-term U.S. resident.
Current law and the new legislation applies to any individual who (i) has a net worth of $2 million or more; (ii) has an average net U.S. income tax liability of greater than $124,000 (adjusted for inflation as of calendar year 2004); or (iii) fails to certify under penalty of perjury that he has complied with all U.S. federal tax obligations for the preceding five years (a 'covered expatriate').
Key Changes under the Legislation
Mark-to-Market Tax on Expatriates
i. Certain deferred compensation items; ii. Certain tax deferred accounts; iii. or Certain interests in a non-grantor trust.
i. Certain deferred compensation items;
ii. Certain tax deferred accounts;
iii. or Certain interests in a non-grantor trust.
Gifts and Bequests from Expatriates
Repeal of 10-year reporting and taxing requirements: