The determination of tax obligations when relinquishing United States citizenship or terminating long-term residency involves a complex calculation. This process assesses potential tax liabilities on unrealized capital gains as if assets were sold on the date of expatriation or termination of residency. This calculation is often necessary for individuals meeting specific net worth or income thresholds.
The significance of understanding this process lies in ensuring compliance with U.S. tax law and minimizing potential penalties. Historically, the need for such calculations arose from concerns about high-net-worth individuals avoiding U.S. taxes by renouncing citizenship or residency and moving assets offshore. Accurate calculation is important for wealth planning purposes.