Countries with U.S. Income Tax Treaties & Lawful Permanent Residents (“Oops – Did I Expatriate”?)

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The U.S. has income tax treaties with multiple countries.  My post from yesterday briefly explains how a LPR living in one of these countries may become a “covered expatriate” if the three conditions of the statute, IRC Section 7701(b)(6) that was added into the law in 2008 are satisfied.  See, LPR status can be abandoned for tax purposes (since 2008 tax law changes) by merely leaving and moving outside the U.S. in some cases. Posted on April 28, 2014

Importantly, a LPR who resides in one of these countries where he or she has income tax residency in the treaty country, can inadvertently “expatriate” for U.S. federal income, estate, gift and inheritance taxes.  See, Oops…Did I “Expatriate” and Never Know It: Lawful Permanent Residents Beware! International Tax Journal, CCH Wolters Kluwer, Jan.-Feb. 2014, Vol. 40 Issue 1, p9

The list of those countries with income tax treaties are as follows and can be reviewed at IRS website:

AEurope Map

Armenia
Australia

Austria
Azerbaijan

B

Bangladesh
Barbados
Belarus

Belgium
Bulgaria

C

Canada
China
Cyprus
Czech Republic

D

Denmark

EMiddle East Map

Egypt
Estonia

F

Finland
France

G

Georgia
Germany
Greece

H

Hungary

IAsia Map - including Russia

Iceland
India
Indonesia
Ireland
Israel
Italy

J

Jamaica
Japan

K

Kazakhstan
Korea
Kyrgyzstan

L

Latvia
Lithuania
Luxembourg

M

Malta
Mexico
Moldova

Morocco

N

NetherlandsSouth America Map
New Zealand
Norway

P

Pakistan
Philippines
Poland
Portugal

R

Romania
Russia

S

Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland

T

Tajikistan
Thailand

Trinidad
Tunisia
Turkey
Turkmenistan

U

Ukraine
Union of Soviet Socialist Republics (USSR)
United Kingdom
United States Model
Uzbekistan

V

Venezuela

 

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