Irc Section 877

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Irc section 877. Individuals losing united states citizenship within the meaning of section 877 of the internal revenue code of 1986 on or after february 6 1995 and b long term residents of the united states with respect to whom an event described in former subparagraph a or b of section 877 e 1 of such code occurs on or after february 6 1995. The expatriation rules apply to u s. Different rules apply according to the date upon which you expatriated.
The term long term resident has the meaning given to such term by section 877 e 2. Internal revenue code section 877 a 2 c expatriation to avoid tax. The expatriation tax provisions apply to u s.
The term long term resident has the meaning given to such term by section 877 e 2. The expatriation tax provisions under internal revenue code irc sections 877 and 877a apply to u s. Internal revenue code 877.
877 c 2 a i. Resident status for federal tax purposes. The language of irc 877a code section aka internal revenue code is complex and the irs rules are even more complicated.
Expatriation to avoid tax on westlaw. Expatriation is the process of relinquishing u s. The individual became at birth a citizen of the united states and a citizen of another country and continues to be a citizen of such other country and.
Citizens and long term permanent residents aka long term residents. In short a lpr who never becomes a long term resident as that technical term is defined in irc section 877 e 2 can avoid the various taxes that arise from otherwise being a covered expatriate. Findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system.