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US citizenship renunciation – inheritance tax proposal update

In September 2015, the IRS issued proposed regulations to section 2801 of the Internal Revenue Code that would introduce a steep tax for US citizens who receive property from certain persons who renounced their US citizenship and are considered “covered expatriates”. Our firm’s Roy Berg and Kevin Kirkpatrick wrote about such proposals, and their blog provides excellent background information regarding these proposals.

On Dec. 9, 2015, Roy Berg, Paul Barba, and Kevin Kirkpatrick submitted our firm’s comments to the IRS regarding the proposed regulations to section 2801 and will be providing oral comments to the IRS at a hearing in Washington, D.C., on Jan. 6, 2016. We are honoured to have the opportunity to assist the IRS in the development of regulations in this very complex area of the law.