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Taxation based on citizenship

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There is one important exception to the rule of taxation based on residence. Citizens and long-term permanent residents (Green Card holders) of the United States of America pay taxes there regardless of their place of residence, i.e. even if they move their residence outside the US. Therefore, the mere emigration of US citizens does not terminate their US tax liability. The only way for US citizens and long-term permanent residents to terminate their unlimited US tax liability is to relinquish their citizenship, i.e. to expatriate, or to give up their Green Card. The relinquishment of US citizenship or a Green Card usually trigger special taxes, and specialist US tax advice is required to ensure full compliance with the relatively complex rules applying to expatriating from the US.2

There are only a few other countries which have similar tax provisions. In the Netherlands, for example, inheritance tax applies for ten years after leaving the country as long as one remains a Dutch citizen, and only the relinquishment of Dutch citizenship would end the extended inheritance tax liability before this ten year period.

Global Residence & Citizenship Handbook

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