What tax planning strategies can I use before renouncing to minimize the exit tax?
I'm a U.S. citizen with a net worth of about $4 million, including my LLC worth roughly $1.5 million. I plan to renounce my citizenship in about 2 years. I know the exit tax is coming, but I want to minimize the damage legally. Are there legitimate strategies I can use before I renounce? Can I give assets away? Restructure my LLC? Time the renunciation to a low-value year? I want to do this by the book — no aggressive schemes.
Related Questions
I'm renouncing U.S. citizenship. What is Form 8854 and the exit tax?
I've been a dual citizen (U.S. and Australia) my whole life but have lived in Australia since I was 5. I've decided to renounce my U.S. citizenship because the annual filing obligations and FATCA repo...
What is IRC 338 and when would a foreign buyer use a Section 338 election when acquiring a U.S. company?
My investment group from South Korea is acquiring 100% of a U.S. C-corporation. Our M&A attorney mentioned making a 'Section 338 election' that would treat the stock purchase as an asset purchase for ...
What is a Section 338(g) election and when is it used for foreign acquisitions?
Our U.S. parent is acquiring a foreign target company by purchasing all of its stock. Our M&A advisor mentioned we should consider a Section 338(g) election to treat the stock purchase as an asset pur...
Form 5472 valuation: when can I use a reasonable estimate instead of an exact amount?
I have an intercompany services charge between my foreign-owned Wyoming LLC and my parent company in Singapore, but I can't get the exact figure until the parent's books close in late April. Form 5472...
I want to surrender my green card. What are the tax steps I need to take for my LLC?
I've decided to surrender my green card and move back to Brazil. I've had the card for 10 years and own a Delaware LLC. I know there's an exit tax and Form 8854, but I need a practical checklist of wh...
What is the U.S. expatriation tax (exit tax) and who does it apply to?
I've been a U.S. green card holder for 12 years and I own a profitable LLC. I'm considering renouncing my green card and moving back to my home country permanently. A friend told me there's an 'exit t...
Can I legally pay zero tax by combining UAE residency with a U.S. LLC?
I'm considering relocating from the UK to Dubai specifically to take advantage of zero personal income tax. I plan to keep my U.S. LLC and run my consulting business from Dubai. Is this legal? What ar...
How do I know if I'm a 'covered expatriate' for exit tax purposes?
I'm planning to surrender my green card next year. My net worth is around $1.8 million, so I think I'm under the $2 million threshold. But I've heard there are other tests too. My LLC generates good i...
I sold a small U.S. business on a note while living abroad. Does Form 6252 still work if I am a foreign seller and the deal included goodwill, equipment, and inventory?
I am based in Germany and sold a U.S. e-commerce business for about $310,000. The buyer paid $60,000 at closing and signed a three-year note for the rest. The deal included brand goodwill, a customer ...
Can I use the Closer Connection Exception to avoid U.S. tax residency even if I meet the Substantial Presence Test?
I own a Wyoming LLC and I spent 135 days in the U.S. this year, plus about 100 days in each of the prior two years. When I run the weighted formula, I come to about 185 days, which puts me over the 18...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
