Guidance on Section 877A

Michael A. Spielman (attorney, Cleveland, OH) recently published his article entitled Service Issues Guidance on Section 877A Exit Tax, 29 News Quarterly 11 (Winter 2010).

The abstract available on SSRN is below:

In June 2008, a new expatriation provision, section 877A, was enacted by the Heroes Earnings assistance and Relief Tax Act of 2008 (“HEART ”). Section 877A applies to certain individuals who, on or after June 17, 2008, relinquish their U.S. citizenship or cease to be a lawful permanent resident of the United States. In addition to a brief background on section 877A, this article provides highlights of the 65 pages of written guidance on section 877A in Notice 2009-85, 2009-45 I.R.B. 598.