Renounce US citizenship — but plan to minimize the §877A mark-to-market exit tax first.
US citizens/long-term green-card holders (8+ years) can renounce/relinquish, ending future US tax obligation. Covered expatriates (>$2M net worth, >$200K avg tax, or non-compliant) face §877A mark-to-market exit tax on ALL unrealized gains above ~$890K exclusion. Planning: gift below thresholds pre-expatriation, time low-income year, use §877A(g)(1) 2018-plus grandfathered pension, deferred-tax election on illiquid assets. Retain estate/GST tax on future US gifts to US persons (§2801).
Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.
Exclude ~$130K/yr of foreign-earned income + housing exclusion — bona fide resident or 330-day test.
Dollar-for-dollar credit for foreign income taxes paid — no cap, no phase-out.
US shareholder of CFC elects corporate rates + FTC on GILTI, cutting rate from 37% to ~21%.
Establish residency in a 0-tax or territorial-tax country to escape US state tax + optimize CFC.
HSBC Expat, America Mortgages, Waltz, MBanc — 30-yr fixed US real estate loans for non-residents.
Non-US jurisdictions with no recognition of foreign judgments — bulletproof asset protection.
Claim treaty position to be taxed as resident of only ONE country, halving your compliance.
Non-resident aliens can own a US LLC, do US business, and pay $0 US tax if properly structured.