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Topic: Saverin expatriation.  (Read 1515 times)

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Saverin expatriation.
« on: May 18, 2012, 12:41:30 PM »
One sure fire way to annoy Americans is to relinquish US citizenship. I believe that Saverin will be paying the expatriation tax and will continue to pay any US tax due, but that gets lost in the volume of the outrage. Saverin will also find it much easier to invest his money outside the US as a non-US citizen. I have also considered expatriation, not to avoid paying US tax, but to make my taxes less complicated and to make my financial life easier in the UK.

http://www.nydailynews.com/news/money/facebook-co-founder-eduardo-saverin-banned-united-states-experts-article-1.1079936

There is already a 30% tax on income, gains etc paid to NRAs, but US tax treaties usually modify that, so the Schumer law is undermining US treaty obligations.

The thing is it would only come into force if you are expatriating for "tax reasons". So if you go ahead, expatriate and end up paying the greater 30% tax surely that shows that you did not expatriate for tax reasons.........also the greater 30% tax rate will reduce the capital gains that you'll have to pay in your country of residence as you'll have a greater FTC.
« Last Edit: May 18, 2012, 03:12:21 PM by nun »


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Re: Saverin expatriation.
« Reply #1 on: May 18, 2012, 05:22:20 PM »
Eduardo Saverin will do fine, but as usual, we'll suffer the collateral damage from the B52 wide-area bombers in the Senate. Their motto seems to be:

"Better that ten innocent men suffer than one guilty man escape"


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Re: Saverin expatriation.
« Reply #2 on: May 19, 2012, 01:58:55 PM »
I'm a bit confused about something in this Saverin case. I was under the impression that tax law already imposes a 30% tax on capital gains connected with US based businesses paid to NRAs unless that is reduced by some tax treaty. I don't think the US has a tax treaty with Singapore so how is Saverin so much better off from a tax perspective? He had to mark-to-market the gain on his Facebook shares when the expatriated and pay 15% CGT and won't he now have to pay 30% on any additional gains? or does he just have to pay the gains on the price as of his expatriation date? If so that's a massive loophole. Of course if Facebook shares go down below the mark to market price I assume he'd be worse off from a tax perspective.
« Last Edit: May 19, 2012, 02:55:20 PM by nun »


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Re: Saverin expatriation.
« Reply #3 on: September 20, 2012, 06:14:32 PM »
I found a pretty good article on the Saverin expatriation ....

http://emergingmoney.com/politics-markets/facebook-cofounder-eduardo-saverin-citizenship-renunciation-not-about-taxes/ [nofollow]


The author has several other relevant articles for Americans abroad on his financial planning website aimed at American Expats:

American Expat Financial Planner [nofollow]


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Re: Saverin expatriation.
« Reply #4 on: September 27, 2012, 09:22:45 PM »

The author has several other relevant articles for Americans abroad on his financial planning website aimed at American Expats:

American Expat Financial Planner

On the link above there's a good overview of investing for US expats. It goes over the issues from a US perspective, like avoid PFIC and you should invest in US accounts and have a local bank account. However, while it emphasizes that local advisers don't understand the US rules and regs, it fails to mention the potential need for local financial and tax planning.


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Re: Saverin expatriation.
« Reply #5 on: October 03, 2012, 10:47:13 PM »
On the link above there's a good overview of investing for US expats. It goes over the issues from a US perspective, like avoid PFIC and you should invest in US accounts and have a local bank account. However, while it emphasizes that local advisers don't understand the US rules and regs, it fails to mention the potential need for local financial and tax planning.

Here is a new article more relevant to PFICs and UK citizens:

Please see Americans in the UK Need to Avoid this Catch-22 Investment Trap [nofollow]


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