arbiter
JournalsPricingAccount

Selected US Tax Developments: Examining the US Income Tax Rules Applicable to US Expatriates

Michael J. Miller

Canadian Tax Journal2025https://doi.org/10.32721/ctj.2025.73.2.ustdarticle
ABDC A*
Weight
0.50

What the paper says

US citizens and resident aliens are subject to income taxation on worldwide income, as well as gift and estate taxation on worldwide assets. Avoiding those rules by becoming a non-resident alien can yield substantial US tax benefits. In order to minimize the US tax benefits of expatriating, a variety of special rules apply to certain individuals who relinquish their US citizenship or cease to be "long-term residents" of the United States. This article discusses the special income tax rules applicable to "covered expatriates."

Open paper page →

Cite this paper

https://doi.org/https://doi.org/10.32721/ctj.2025.73.2.ustd

Or copy a formatted citation

@article{michael2025,
  title        = {{Selected US Tax Developments: Examining the US Income Tax Rules Applicable to US Expatriates}},
  author       = {Michael J. Miller},
  journal      = {Canadian Tax Journal},
  year         = {2025},
  doi          = {https://doi.org/https://doi.org/10.32721/ctj.2025.73.2.ustd},
}

Paste directly into BibTeX, Zotero, or your reference manager.

Flag this paper

Selected US Tax Developments: Examining the US Income Tax Rules Applicable to US Expatriates

Flags are reviewed by the Arbiter methodology team within 5 business days.

Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.