Monday, December 19, 2011
It has been more than three years since the enactment of Sec. 877A, which introduced a mark-to-market tax on U.S. persons expatriating on or after June 16, 2008.
Official records indicate that, although still relatively small, there is an increasing number of U.S. persons who have renounced, or are in the process of renouncing, their U.S. citizenship or...