The US might have the most complex international taxation and information disclosure rules in the world. The US is the only industrialized country that taxes its citizens on worldwide income. The Internal Revenue Service (IRS) has been aggressively enforcing the intricate income and information reporting / financial disclosure rules, leading to such items as the Offshore Voluntary Disclosure Program (OVDP) and Streamlined Foreign / Domestic Offshore Procedures. As an example, many people simply don’t know they must disclose the existence of foreign bank accounts, even if someone is a US citizen but hasn’t lived in the US for several years (or ever).

Because of the tax system, more people than ever have been renouncing citizenship and abandoning Green Cards. Based on specific laws passed by Congress, renouncing citizenship is a taxable transaction, and so is abandoning a Green Card in certain situations.

This course discusses the specific US rules on expatriating. It also discusses the general rules for US persons transferred to foreign companies, including practical implications of the transfer and the impact on global after-tax cash flow.