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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

Abstract

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."

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

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@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},
}

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

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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

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