Event 14 Oct. 2022
Curtis Provides Capacity Training to the Government of Uganda
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Event 21 Sep. 2022
Kalidou Gadio Speaks at AIEN 2022 International Energy Summit
Event 06 Jun. 2023
Partner Borzu Sabahi Speaks on Panel in Tashkent Law Spring International Legal Forum in the Republic of Uzbekistan
News 15 May. 2023
Curtis represents e-commerce retailer in its fight to recover monies withheld by PayPal, the global payment giant
Event 08 May. 2023
Partner Irene Petrelli to Participate in ICC YAAF Event
News 02 May. 2023
Curtis Italy with DeA Capital in the Acquisition of Magic S.r.l
Event 07 Jun. 2023
Elisa Botero Speaks on Latin America’s H2 Potential at AIEN’s International Energy Summit
Event 23 May. 2023
Partners Luciana Ricart and Fernando Tupa Will Teach a Workshop on Hearings in Investment Arbitration for Arbanza School of Arbitration’s Online Program
Event 03 May. 2023
Dr. Borzu Sabahi to Speak at ICSID-ADGM Joint Conference: Investment Protection and Armed Conflict
Event 19 Mar. 2023
Sebastiano Nessi speaks at Bahrain Business and Legal Landscape Conference
Event 01 Jun. 2023
Curtis Environmental Chair Charles Howland to Moderate Panel Discussion on Latest Developments in Environmental Due Diligence at ABA Masterclass on Environmental Transactions
News 25 May. 2023
Curtis Files SCOTUS Amicus Brief for Distinguished Law Professors in First Amendment Retaliatory Arrest Case
News 06 Mar. 2023
Russia Sanctions at the First Anniversary: An Overview of Current Sanctions in the US, UK, and EU and How Global Companies Can Navigate Evolving and Conflicting Sanctions Regimes
Client Alert 30 Aug. 2022
The EU Adopts the “Maintenance and Alignment” Sanctions Package
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
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.
Individuals Covered
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:
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