Document Type

Article

Publication Date

2023

Abstract

Code Sec. 877A was enacted in 2008 to impose a significant price on U.S. cit-izens who expatriate. But the price is not right. The quarterly data on expatri-ations (published in the Federal Register since 1998) show an increasing trendsince 2008. For example, 3,422 Americans expatriated in 2022, and the averagesince 2013 was 3,239. By comparison, between 1998 and 2012, fewer than1,000 Americans expatriated each year. This paper will discuss why the increasehappened and what Congress can do about it.

Comments

© 2023 R. S. Avi-Yonah. This article is reprinted with the publisher’s permission from International Tax Journal, a bimonthly journal published by CCH Incorporated. Copying or distribution without the publisher’s permission is prohibited.

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