Editorial/Reconciliation/Dom Rep wedding changes/Renouncing US citizenship
THE EDITOR SPEAKS: IDLE THOUGHTS
Colin Wilson
I was asked over this weekend to conduct a brief discussion at a men’s Group I belong to whilst we broke for refreshment and to to come up with a title for it as it was proposed to become a regular feature.
I came up with the title, “Idle Thoughts”. ‘Idle Thoughts’ actually started off one of my wife Joan’s, first published poems, “Idle Thoughts of Yester Year”. She said she was looking out of her office window in George Town watching people walking around. She compared life now with life when she was a child and described the many changes as the years passed her by.
The response to the piece was so positive I have decided to share it with you:
We all have “idle thoughts” even though we may not be conscious of them. We all stop for a rest from our hectic life but our mind keeps turning.
Jerome K. Jerome, a famous author in 1886 (he’s still dead by the way) said “It is impossible to enjoy idling thoroughly unless one has plenty of work to do. There is no fun in doing nothing when you have nothing to do. Wasting time is merely an occupation then, and a most exhausting one.”
My idle thoughts also tend to go back in time. One such idle thought came to me from the last meeting we had. I was playing checkers with brother Voot who wiped the floor with me at Checkers by “huffing me”. Then he humiliated me again at Chess. So my idle thoughts ranged on how I could get even with him.
In the nicest possible way, of course. The trouble is I couldn’t think of anything because you see my thoughts weren’t idle now that I was trying to plan something.
Do we have idle thoughts about faith? If they are idle it is OK because there doesn’t have to be a smart conclusion. That, again, demands a working mind.
I had an idle thought about my faith when I watched some appalling video on BBC World of children being burned and killed at a school in Syria by a napalm-like substance that was in a bomb dropped on them by a Syrian Military plane.
10 children were killed and many more were injured. I watched all this horror and my faith disappeared. I had none. All of Christ’s teachings about love and forgiveness were forgotten as if I had never heard them. Christ’s name never came to mind. I didn’t even question God? I idly sat there watching this horror permeating into my home sitting room and I thought “why?” Why does man want to do this and to innocent children? What benefit does it do for the person who perpetrated this? Why am I watching it? I didn’t question why I didn’t reach for the remote and turn it off. I sat there idly.
I finally awoke this idleness when I heard someone say,
“The worst thing in life is watching someone die right in front of you and you can’t do anything. There were dead people, people burning and people running away, but where to? Where would they go? It is not safe anywhere. That is the fate of the Syrian people.”
The voice that came from the television was from the headmaster of the school where the children had gone that day to learn. And they certainly learnt something and it wasn’t love.
Or was it?
Because, when my idle thoughts had stopped idling and emotions started forming in my brain there was much hate, and tears flooded down my face. However, in all this carnage and horror I actually saw love.
There was a young woman there. She was British and she was a doctor. She had gone to Syria because she knew that was where she was needed most. She worked for a charity called “Hand in Hand” and she was there showing much love as she carried out the professional skills God had given her. She tended to these children with tenderness and kindness. These children whom she had never seen before that day recognised her love and ran crying into her arms.
Can you imagine if there was only hatred in this world?
Later, the doctor was interviewed and as she took a rest she said something that hit home.
She said, “The whole world has failed Syria and it is innocent civilians who are paying the price.”
Later on in that news bulletin I heard the United Kingdom Government had voted against the British Prime Minister’s call to take action against Syria’s government for using chemical weapons against their own people.
I thought, so we will watch and do nothing?
However, what would taking an eye for and eye and a tooth for a tooth action do?
Hasn’t any of us tried a different approach? LOVE?
Is ‘love’ an idle thought? In all of Joan’s idle thoughts of yesteryear there was much love. Far more love than hate. There was love from her parents and her brothers and sisters who were all older than she. All through her life she has encountered love. So many, many times more than hate.
In all our lives we encounter love. Much love.
Even in Syria with all those atrocities there is love as that British doctor proved. And she wasn’t the only person there showing love.
So I leave you with these idle thoughts to ponder?
We are all Christian men. In adversity would we fight back with love? Can we show love to persons who murder, maim, rob, threaten and perform the atrocities I watched idly on television being executed in Syria?
Love does work. It worked recently and almost the same time as the Syrian atrocities were taking place.
In Atlanta a man slips behind someone else into a packed elementary school with an AK-47-type weapon. He goes into the office and shoots at the ground, then darts between there and outside to fire at approaching police.
So what do you do?
If you’re Antoinette Tuff, who works in the front office at Ronald E. McNair Discovery Learning Academy just outside Atlanta, you don’t run. You talk. You divulge your personal struggles to the gunman, you tell him you love him, you even proactively offer to walk outside with him to surrender so police won’t shoot.
And then the nightmare ends with the gunman, taken into custody and no one inside or outside the Decatur school even hurt, despite the gunfire.
She told him she loved him.
Now what would have happened if she had acted with hate? Confronted him telling him how evil he was and how she loathed him. What would have happened if the police had stopped her from talking to him and opened fire?
We are taught as Christians to show love in everything we do. Have hope. Have faith. Have love. And the greatest of all is love.
And let love invade all our idle thoughts.
END
The discussion followed on what would have happened if love had been shown to Syrian president, Assad? The consensus was it would have been viewed as weakness.
What do you think?
APPRECIATING THE SOUTH AFRICAN MODEL OF RECONCILIATION IN THE CARIBBEAN
From Rabbi Dana Kaplan The Huffington Post
During this time of year, Jews around the world start to think about for forgiveness. My thoughts have taken me one step further. I have been considering how we Jamaicans can utilize forgiveness to expand our sense of spirituality, how it can motivate us to move past our violent past to develop a peaceful society. I believe the Jewish character building discipline of Mussar can play a crucial role in this process.
The Oxford English Dictionary defines forgiveness as “granting free pardon and giving up all claim on account of an offence or debt.” Merriam Webster describes it as “ceasing to feel resentment against an offender.”
I would explain forgiveness as the renunciation of anger, resentment, and/or indignation as a result of a perceived offence. It is done — at least in part — in order to prevent the wrong from continuing to damage one’s psyche. Forgiveness is most meaningful when it occurs in the right way and for the right reason(s).
Last year, our congregation in Kingston, Jamaica, began studying a modern form of Mussar, the Jewish approach to ethical living founded in Eastern Europe. We organized a beginners group in the fall and a more advanced group in the spring. Each group combined textual study with personal discussion of character and specific character traits.
We looked at both of the most popular modern approaches — that of Rabbi Ira Stone and that of Alan Morinis. From a purely personal point of view, I found both lacking but nevertheless became convinced that a modernized form of Mussar was essential for synagogue life today. I am in search of an approach that is more scholarly and liberal than that of Morinis and more accessible than that of Stone. This will be an ongoing search for a systemic approach to the study of Jewish values for daily living.
For this coming year, we have decided to continue the advanced group, start a new introductory group, and highlight one Mussar trait each month for the entire congregation. We will begin with “forgiveness” in September, continue in October with “humility” (the core concept necessary for all the others), “courage” in November in time for Hanukkah, and “joy” in December. Our hope is to have those in the groups serve as the vanguard for the entire congregation to begin to connect the study of character with what we do in the synagogue, thereby helping us to see the connection between ritual and daily living.
Forgiveness seemed an appropriate concept for the High Holy Day season. It also resonated strongly within me because of my earlier experiences in South Africa. Most of all, it is central to living our lives to the fullest. If we cannot let go of old wounds and failures that occurred over the course of the decades, we risk losing our ability to live in the moment, to truly savor what is central for a rich spiritual life.
Going back in history, the people of Jamaica were deliberately split into two warring factions in order to maintain the colonial order. There is a dire need for forgiveness of others and also ourselves as a part of the process of communal and national reconciliation.
Reconciliation is possible only when the person who did the wrong accepts the forgiveness being offered and repents for what they have done. This can be done on a personal basis but also on a national level. Jamaicans should look to South Africa as a model of national reconciliation.
Despite the ups and downs in that country since the end of apartheid almost 20 years ago, most South Africans are still hopeful about the possibility of reconciliation. While Jamaica has not had to go through a parallel process, in many ways the lessons of South Africa are applicable to this Caribbean paradise, a country that has not yet achieved its potential due to unresolved anger and an inability to focus on the most important priorities.
Archbishop Desmond Tutu, whom I invited to speak at my synagogue in 1995, wrote:
“Forgiveness is one of the key ideas in this world. Forgiveness is not just some nebulous, vague idea that one can easily dismiss. It has to do with uniting people through practical politics. Without forgiveness there is no future. Forgiveness is taking seriously the awfulness of what has happened when you are treated unfairly. It is opening the door for the other person to have a chance to begin again. Without forgiveness, resentment builds in us, a resentment which turns into hostility and anger. Hatred eats away at our well-being.”
(Tutu refers to Ubuntu, which is difficult to render in English but has a similar meaning.)
One thing is for certain. Despite the trepidation with which many South Africans approached the possibility of reconciliation, the need for forgiveness is a core element of any hope for the future.
Forgiving is incredibly difficult in the best of circumstances, and the South African situation was far from the best of circumstances. Nevertheless, it is remarkable to see the tenacity with which almost all of the parties in the South African ethnic, religious, and racial mix have persevered with the forgiveness process. Despite political difficulties and the tendency to radicalize politics, the country has remained a relatively peaceful, if crime-ridden, “rainbow nation.”
The idea is that forgiveness, in politics as well as in interpersonal relationships, must be an ongoing process rather than something that is to be applied at one place and at one time. The notion of forgiveness as a process rather than an event appears to be a lesson that all of the groups instinctually sense and have worked on over the course of many years. Jamaicans can learn from this approach. Lacking a clear internal enemy with which we might reconcile, we need to internalize the core concepts of the forgiveness process and then apply these concepts to our neighbors, our friends, even ourselves. A spirit of forgiveness can inspire the people of Jamaica to achieve things they never thought possible when they were caught in the negative cycle of blame, hostility and violence.
The South African Truth and Reconciliation Commission (TRC) tried to develop a process that involves remembering, recounting, and recording, but also that includes repenting, resolving, and reconciling. Those who have done wrong were encouraged to recount the full details of their passive or active crimes to the TRC and were, therefore, achieving repentance.
The idea that justice must be meted out has been relegated to the back row. In order to achieve the healing that is felt to be the highest priority for the society, the needs of the victims and their families for absolute justice have been given a lower priority.
In Jamaica, we need to learn how to forgive (ourselves as well as others) so that we can move forward. We need to resolve to work together, something which is only possible if we can rid ourselves of our antagonisms.
Our congregation will do our part. We hope the rest of the Jamaican population will follow our lead.
For more on this story go to:
http://www.huffingtonpost.com/rabbi-dana-kaplan/appreciating-the-south-af_b_3836592.html
DOMINICAN REPUBLIC ALLOWS NON-CATHOLIC WEDDINGS
From Boston.com
PHOTO: Bride Leidy Laura Cabreja signs a marriage license as her groom Baldwin Rodriguez looks on during their Jehovah’s Witness wedding ceremony in Santo Domingo, Dominican Republic, Wednesday, Aug. 28, 2013. The couple became the first pair to marry under a new law recognizing religious weddings not held in a Roman Catholic Church. Previously, marriages received legal recognition only if held at the civil registry or in a Catholic ceremony. (AP Photo/Ezequiel Abiu Lopez)
SANTO DOMINGO, Dominican Republic (AP) — An evangelical couple in the Dominican Republic has become the first pair to marry under a new law recognizing religious weddings not held in a Roman Catholic Church.
The newly effective law allowed Baldwin Rodriguez and Leidy Laura Cabreja to have an officially recognized Jehovah’s Witness wedding ceremony Wednesday.
Instead of holding it at their church, though, the couple was married at the headquarters of the Central Electoral Board, which oversees civil records. That was so they could immediately have their marriage certificate recorded.
Freedom of worship did not receive constitutional protection until 2010 in the Caribbean country, where more than 80 percent of the 10 million inhabitants are Catholics.
Previously, marriages received legal recognition only if held at the civil registry or in a Catholic ceremony.
© Copyright 2013 Globe Newspaper Company
For more on this story go to:
CANADA: RENOUNCING YOUR US CITIZENSHIP
By Alexander Marino From Moodys Tax Advisors
Canada: Renouncing Your US Citizenship: Failed Amendment May Signal That Now Is The Time To Get Out!
If you are one of the many US citizens contemplating renouncing your US citizenship, Congress recently sent a fairly clear message that now, as opposed to later, may be the right time to get out of the club. On June 12, 2013, US Senators Jack Reed (D-RI) and Chuck Schumer (D-NY) attempted to add yet another hurdle in the ongoing saga for those individuals looking to renounce their US citizenship in filing an amendment to the immigration reform bill, which attempted to ensure that the US Department of Homeland Security could exclude certain individuals from re-entry into the US forever. The proposed amendment was never voted on in the House and died before reaching the floor. If the proposed amendment had made its way into law, it would have excluded from re-entry not only former US citizens who renounce for tax avoidance purposes (as is the current law), but also renouncing individuals who are considered “Covered Expatriates” under Internal Revenue Code § 877A.
What is most important to take away from this failed passage of legislation is that the issue of renouncing one’s US citizenship is again front and center on Congress’s radar and the only guarantee moving forward is that any potential changes will not make things any easier to get out. The first quarter of 2013 saw the highest number of US citizens renouncing in history. This record number of US citizens looking to get out represents substantial losses in the number of taxpayers and tax dollars collected on behalf of the IRS (during life and at death). Congress is clearly aware of this fact and appears poised to put the brakes on the mass exodus.
Under the failed amendment, a renouncing individual who was classified as a Covered Expatriate under § 877A, would have had to prove to the Department of Homeland Security by “clear and convincing” evidence that he or she did not renounce for tax avoidance purposes. The burden of proving this negative would have fallen on the renouncing Covered Expatriate if he or she desired to ever re-enter the US.
So how does a renouncing US citizen become a Covered Expatriate under § 877A? Section 877A defines a Covered Expatriate as an individual who meets the requirements of subparagraph (A), (B), or (C) of § 877(a)(2). Section 877(a)(2) classifies a renouncing US citizen as a Covered Expatriate if he or she meets one or more of the following criteria:
1. has an average annual net tax liability for the five preceding years of more than $155,000 US (2013 amount adjusted for inflation);
2. has a net worth of over $2,000,000 US; or
3. fails to certify compliance with US tax obligations for the prior five years (discussed in further detail infra). 1
When questioned regarding the proposed amendment, Senator Reed stated:
“American citizenship is a privilege. But it seems that a privileged few are trying to game the system by accumulating wealth and benefiting from the greatness of the United States and then renouncing their citizenship to avoid paying their fair share of taxes. They are welcome to leave our country, but they should not be welcomed to return without playing by the rules and paying what they owe.”
While the failed passage of this amendment is a clear victory for those looking to renounce their US citizenship in the near future, the fact that Congress has already attempted to bring legislation before the floor in an effort to make the penalties associated with renouncing even more severe, should send a loud and clear message to all those looking to renounce their US citizenship…”GET OUT NOW”.
Where The Law Was Headed Under The Failed Reed-Schumer Amendment
The original Reed Amendment, and current law (discussed below), was passed in the 1990’s. Fast forward almost two decades and the same issues regarding the lost US tax revenue of expatriates still exists today. The proposed and rejected Reed-Schumer Amendment would have changed the current law governing the renunciation of US citizens by:
1. Automatically excluding any Covered Expatriate that triggers the expatriate exit tax under § 877A;
2. Creating a mechanism to allow a Covered Expatriate (individual caught under § 877A) to petition the US Department of Homeland Security for a determination that tax avoidance was not one of the principal purpose of expatriation; and
3. The Department of Homeland Security may make that determination if the Covered Expatriate can establish through clear and convincing evidence that tax avoidance was not one the principal purposes for the expatriation.
In a nutshell, all Covered Expatriates would have had the burden of proving that tax avoidance was not a primary purpose of their renunciation. Under the original Reed Amendment, the burden is with the US government to show that the renouncing US citizen did so to avoid US tax. This shifting of the burden of proof is enormously important and greatly increases what is at stake for a Covered Expatriate. Under the original Reed Amendment the advantage was clearly with any renouncing US citizen (whether a Covered Expatriate or not). It can be very difficult for the US government to meet its burden of proof regarding tax avoidance motives. Under the failed Reed-Schumer Amendment, the advantage would have been squarely with the US government when dealing with a Covered Expatriate.
If similar legislation to the failed Reed-Schumer Amendment later becomes law, the importance of avoiding the US exit tax under § 877A will be even more important than before. Not only would the repercussions of being classified as a Covered Expatriate under § 877A result in a deemed disposition of the renouncing individual’s worldwide assets under the exit tax rules, but the burden to prove that a primary purpose of the renunciation was not to avoid US tax, would have fallen on the Covered Expatriate and not the US government.
This automatic presumption of having renounced for tax avoidance purposes would have resulted in the Covered Expatriate having to retain counsel and present evidence before the Department of Homeland Security to prove that he or she did not renounce for tax avoidance purposes. The burden of proving a negative is extremely difficult in any situation. The result would be that the Covered Expatriate would have been required to spend time and resources fighting an uphill battle of proving through “clear and convincing evidence” that a principal purpose in their renunciation was not to avoid US tax. The Covered Expatriate would have been forced to make a circumstantial argument before the Department of Homeland Security in hopes that the governing body involved sees the facts in the taxpayer’s favor. If not, the Covered Expatriate would have been denied re-entry into the United States in addition to being hit with the exit tax.
Where The Law Stands Today: The Original Reed Amendment
In the early 1990’s, a highly publicized renunciation case involving Mr. Kenneth Dart was at issue. Mr. Dart was a billionaire who decided to renounce his US citizenship in an effort to avoid paying US tax, became a citizen of Belize, and was then appointed by the Belizean government to be a consular officer in Sarasota, Florida. These strategic decisions allowed Mr. Dart to continue to live and work in the US, without paying any tax on the hundreds of millions of dollars he had accumulated in the US, as a US citizen.
As a result, in 1996 Senator Reed proposed, and passed into law, the original Reed Amendment, further governing the treatment of expatriates who renounce their US citizenship for the primary purpose of tax avoidance.2 The law still stands today and allows the Executive Branch3 the ability and authority to determine which US citizens have renounced for tax avoidance purposes. If it is determined that the US citizen renounced for the primary purpose of avoiding US tax, that person will be denied re-entry into the US.4 While the law currently governing this issue gives the Executive Branch the ability to make the determination of tax avoidance, its successful application is very rare.
The reason so few expatriates are classified as having done so for tax avoidance purposes under the original Reed Amendment is because the burden to establish the renouncing expatriates tax avoidance motives falls squarely on the Consular Officer assigned to conduct the exit interview. The exit interview is the final stage of the renunciation process and is done at a US Consulate location. Under the original Reed Amendment, the burden is on the Executive Branch to prove that the US citizen is renouncing with the primary purpose of tax avoidance.
However, in the practical application of the original Reed Amendment, the renouncing individual is rarely denied re-entry to the US unless he confesses during his exit interview to be renouncing for tax avoidance purposes. Needless to say, very few expatriates renouncing their US citizenship confess to having tax avoidance purposes. Consequently, identifying those expatriates who renounce for tax avoidance purposes is nearly impossible. Congress knows this and is attempting to tighten the screws on the renunciation program through the proposed Reed-Schumer Amendment.
§ 877A: Avoid Being A “Covered Expatriate”
Avoiding being classified as a Covered Expatriate under § 877A will take on an even greater importance if future legislation similar to that of the failed Reed-Schumer Amendment ever becomes law in the weeks, months, or years to come. As the law currently stands, avoiding § 877A and the US exit tax is very important. Standing alone, the exit tax can have devastating tax consequences to a renouncing US citizen who is not prepared accordingly. Assuming a variation of the Reed-Schumer Amendment one day becomes law, the scope and effect of not being labelled a covered expatriate under § 877A cannot be understated.
Section 877A was enacted in 2008 under the Heroes Earnings Assistance and Relief Act and established a more stringent exit tax regime applicable to a Covered Expatriate. Section 877A classifies an expatriate as a “Covered Expatriate” when the individual meets any one portion of a three part test and renounces their US citizenship or loses US residency5 after June 17, 2008. A Covered Expatriate subject to the exit tax under § 877A will face a mark to market exit tax regime in which the provision treats the covered expatriate as having sold all of their property the day before the “expatriation date” for its fair market value.6 The “expatriation date” is the date that the taxpayer renounces citizenship or ceases to be a lawful permanent US resident.7 The mark to market exit tax regime applies to unrealized net gains in excess of $651,000 US in 2012 (adjusted annually).8 The mark to market rules deviate in application to any deferred compensation items, 9 specified tax deferred accounts, 10 and to interests in non-grantor trusts. 11 The three part test of the statute, as discussed above, will classify an individual as a “Covered Expatriate” if any of the following statements are true:
1. The individual has a net worth of $2,000,000 US or more at the time of renunciation (Net Worth Test);
2. The individual had an average annual net income tax liability of more than $151,000 US in the five years ending before the date of expatriation (Tax Liability Test); or
3. The individual failed to certify on Form 8854 that he or she had complied with all US Federal tax obligations for the five years preceding the date of expatriation (Compliance Test).
There are two main exceptions to the exit tax regime for US citizens looking to renounce and not be considered Covered Expatriates. The first exception is largely limited to dual citizens who live in the country of their other nationality. The second is even narrower and is limited to citizens who did not live in the US for more than ten years before the age of eighteen and a half. As minors are generally not allowed to renounce their US citizenship, it effectively allows only a six month window for such individuals to avoid the imposition of § 877A’s exit tax regime. The following are the two exceptions to § 877A’s exit tax regime:
1. An individual is exempt from the exit tax regime if he or she:
a. Files Form 8854;
b. Became a dual citizen at birth and continued to be a citizen and tax resident of the other country (Canada) at the time of renunciation of citizenship; and
c. Was a resident of the US for no more than ten of the fifteen tax years ending with the tax year during which the renunciation of citizenship occurred.
2. An individual is exempt from the exit tax regime if he or she:
a. Files Form 8854;
b. Renounces his or her US Citizenship before the age of 18 and a half; and
c. Was a resident of the US for no more than ten years before the age of 18 and a half.
In the practical application of these two exceptions, a renouncing individual who qualifies under either will not be subject to the Net Worth Test or the Tax Liability Test only. Every renouncing individual, whether qualifying under the exceptions or not, will always be subject to the Compliance Test. Form 8854 is filed with a renounced individual’s final year return. On Form 8854, the renouncing individual must affirm under penalties of perjury, that he is compliant with US tax and filing obligations for the period of five years preceding expatriation. Thus, taking the proper steps to avoid the exit tax regime of § 877A requires that the renouncing individual be US tax compliant in all circumstances.
With every renouncing individual being required to be five years US compliant in order to avoid the classification of a Covered Expatriate under § 877A, a brief review of some potential filling and reporting obligations facing an expatriate looking to get US tax compliant is useful. Appended to this article is a table that summarizes most of the filing and reporting obligations required by US citizens residing in Canada.
Conclusion
The Reed-Schumer Amendment recently failed to become US law, but the danger of inadvertently being barred from the US while also being hit with the US exit tax may still be of real concern for those considering renouncing in the near future and beyond. It is fairly safe to say that Congress is aware of the renunciation problem they are facing, and smart money would be on another amendment or bill attempting to become law in the near future. This fact, accompanied with the Foreign Account Tax Compliance Act (FATCA) set to go into effect in 2014, may make now the best time to renounce one’s US citizenship. The magnitude of what could be at stake when an individual looks to renounce their US citizenship in the future has the potential to be exponentially greater if Congress continues on its path to curb the record number of renunciations in 2013 and beyond. Any US citizen who renounces their citizenship under the current Reed Amendment, or a potential future variation of the failed Reed-Schumer Amendment, needs to understand the repercussions and timing of this decision moving forward.
Click http://www.moodystax.com/downloads/Renouncing-Part2-Appendix.pdf
for a summary of filing and reporting obligations required by US citizens residing in Canada.
Footnotes
1. There are two limited exceptions provided for dual citizens at birth and persons under 18 ½ years of age. These two exceptions make it so that an expatriate will only be a covered expatriate if he or she fails to certify compliance with US tax obligations for the prior 5 years. Thus, these two exceptions can eliminate the need to comply with the tax liability test (IRC § 877 (a)(2)(A)) and the net worth test (IRC § 877 (a)(2)(B)) in attempting to avoid being classified as a covered expatriate (discussed further infra).
2. IRC § 877A(g)(2) provides that an “expatriate” means any US citizen who relinquishes his or her citizenship and any long term resident of the US who ceases to be a lawful permanent resident of the US Long term resident is defined in IRC § 877A(g)(5).
3. US Department of State.
4. 8 U.S.C. § 1182(a)(10)(E)(2011). (Any alien who is a former citizen of the United States who officially renounces United States citizenship and who is determined by the Attorney General to have renounced United States Citizenship for the purpose of avoiding taxation by the United States is inadmissible.)
5. IRC § 877(e)(2). Deemed a long term permanent resident if the individual held a US Green Card for 8 of the previous 15 years.
6. IRC § 877A(a)(1).
7. IRC § 877A(g)(3) and (g)(4).
8. IRC § 877A (a)(3).
9. IRC § 877A(d)(4).
10. IRC § 877A(e)(2).
11. IRC § 877A(c) and IRC § 877A(f)(3).
12. 2012 number. Adjusted annually for inflation.
13. IRC § 877A(g)(1)B)(i).
14. IRC § 877A(g)(1)B)(ii).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
