More Citizens Leaving the U.S.
The IRS has made more efforts to get U.S. taxpayers report of their worldwide income and to disclose their foreign financial accounts. American citizens and U.S. permanent residents who do decide to leave the country are subject to tax issues on the way out. U.S. citizens or long-term residents who expatriate after June 16, 2008 are considered to have sold all of their worldwide property at its fair market value the day before leaving the U.S. and their gain is taxed at a high rate as a capital gain. Some people are not subject to this harsh tax. You can escape the tax if you do not have more than $651,000 of income from the supposed sale of your assets. If your gain does exceed that amount, then you have to allocate the gain pro rata among all of your appreciated property. Because of this, appraisals of property are a good idea.
Even if you owe an exit tax, you may be able to defer it. Either way, there are forms that you must fill out so it is best to get professional advice.
See Robert W. Wood, Celebrity Leavings: Bidding Stars Adieu, Forbes, Feb. 14, 2012.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.