Lesson from @VLJeker: Some people may never be able to renounce US citizenship. Others may have capacity to renounce now but may not have the capacity to renounce in the future. The inability to renounce has implications for estate and life planning and should be taken seriously!
@VLJeker I have and do see cases where the aging process has eroded the capacity to form the intention to renounce. The result is that certain people are forced to continue to live and die as US citizens. While not a problem for US residents, it can be a big problem for #Americansabroad.
Problems of living/dying as @USCitizenAbroad include: 1. US @citizenshiptax regime while alive 2. Estate having to file US tax returns at death 3. Difficulties leaving assets to nonresident alien spouse 4. Possible Estate Tax 5. Estate Tax return to transfer certain US assets
Even "covered expatriates", whose assets are primarily outside the USA, who are subject to the 877A Expatriation tax on renunciation (23.5% on property), may find it less expensive than the tax imposed by the US Estate tax regime (40%).
Living as a @USCitizenAbroad can be difficult. But, dying as a US citizen (who is NOT a US resident) can create a new set of problems. In some cases the problems can be worse! Renunciation is an estate planning consideration. Aging process can erode the capacity to renounce!
More trouble on death: Spouse of US citizen dies leaving assets to @USCitizenabroad increasing net worth so that USC if renounces now a covered expat. Terrible tragedy. Delay in renunciation can be very costly.
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