Trouble Ahead for Certain Green Card Holders: Part ITrouble Ahead for Certain Green Card Holders: Part I

In our global practices spanning cumulatively three quarters of a century, we find that green card holders too often are oblivious to the fact that formal steps must be taken to relinquish their U.S. residency status. Allowing a green card to expire is insufficient, and remaining outside the United States permanently or for long periods of time is inadequate. The Internal Revenue Service Chief Counsel concurs, stating that “merely leaving the U.S. with no intention to return is not sufficient.”¹

Step Up in Enforcement

In 2020, the rapid pre-pandemic expatriation from the United States caught the attention of the U.S. Treasury Inspector General for Tax Administration (TIGTA). As a result, in its Sept. 28, 2020 report, the TIGTA emphasized t...