A Possible Silver Lining for Green Card Holders?A Possible Silver Lining for Green Card Holders?

In our last article,¹ we laid out the reasons why green card holders should comply with their U.S. tax filing obligations while still residing in the United States. Green card holders have certain pre-expatriation planning opportunities available to them if they can plan ahead to enable them to mitigate or possibly eliminate exit tax and inheritance tax. We previously explained the long reach of the U.S. government into foreign countries to recover unpaid penalties and debts due to the U.S. government.

We’ll now focus on long-term residents (LTRs). LTRs are green card holders who have been found to be tax resident in United States for eight of the last 15 years. LTRs may be able to use the dichotomy between the objective tests for U.S. in...