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ARTICLE · 17 JUNE 2005

Global Intouch (June 2005)

Deloitte LLP
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The U.S. imposes income tax on the worldwide income of its citizens and green card holders even if they reside overseas. U.S. citizens and certain green card holders residing overseas are also subject to U.S. gift and estate tax on transfers of worldwide assets.

GlobalAccounting and Audit

EXPATRIATION FROM THE UNITED STATES AFTER 3 JUNE 2004, PART 1

The U.S. imposes income tax on the worldwide income of its citizens and green card holders even if they reside overseas. U.S. citizens and certain green card holders residing overseas are also subject to U.S. gift and estate tax on transfers of worldwide assets. As a result, such individuals sometimes consider relinquishing their citizenship or green card with the hope of freeing themselves from the U.S. tax system. However, giving up U.S. citizenship or a green card does not necessarily provide immediate relief from U.S. taxation.

U.S. citizens and certain green card holders who expatriate from the United States may be subject to alternative income, estate and gift tax regimes for ten years following their expatriation. In October 2004, the American Jobs Creation Act ("AJCA") revised the U.S. expatriation provisions applicable to persons expatriating after June 3, 2004.

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