Five Stone Tax Advisers' Take on an Important Tax-Related Article:
Whether they be a dual-citizen, legal permanent resident, etc., it is important for those persons that have attained status as a United States (U.S.) taxpayer to have a legal analysis completed under federal income tax law before either formally (mark-to-market expatriation) or informally renouncing citizenship.
As illustrated in the article on the Topsnik case, failure to complete this legal analysis can lead to unintended consequences and in Mr. Topsnik’s case, severe tax liability. As the U.S. Tax Court held in his case, the status of legal permanent resident for federal income tax purposes turns on federal income tax law and is only indirectly determined by immigration law.
About Five Stone Tax Advisers
Five Stone Tax Advisers has years of experience negotiating directly with the IRS to get the best possible outcome for you. Our International Tax Advisory and Compliance unit has a team of tax attorneys, certified public accountants and enrolled agents that form a single sourced point of contact that will provide services for all the legal, compliance and financial reconstruction aspects of dual citizen and expatriation cases.