Immigration Law Considerations, Tax Policy

Ausbürgerung – ???? – Expatriación – – ????????? – Expatrié – Ausgebürgerter – ?? – Espatri

By · May 8, 2014 · Updated June 3, 2026

Ausbürgerung – ???? – Expatriación – – ????????? – Expatrié – Ausgebürgerter  – ?? –  Espatri

Each of these terms can have a significantly different meaning, depending upon each country, different histories and distinct cultural experiences.   The meaning of “expatriate” in the U.S. itself has now become a loaded word, meaning different things to different people.

Only recently has the term “expatriate” conjured up tax consequences, largely due to U.S. tax law and the attention it has gotten over the last 5-6 years around the world.  The term “expatriate” or “expatriation” appeared sparingly in the U.S. tax law (less than a dozen times), until modifications made in 2008, which introduced no less than 46 news uses of the term “expatriate” or “expatriation” in Section 877A.

Different countries throughout history have had their own experiences with so-called “expatriates.”  I will write a series of posts that touch upon the meaning of such terms throughout different societies, including in different points of time and history.

Ausbürgerung – ???? – Expatriación – – ????????? – Expatrié – Ausgebürgerter  – ?? –  Espatri

 

 

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Patrick W. Martin

Patrick W. Martin

U.S. International Tax Lawyer · Shareholder, Chamberlain Hrdlicka

Patrick W. Martin is a U.S. tax lawyer licensed in California, Texas, and Washington, D.C., with 32+ years advising on the tax consequences of renouncing U.S. citizenship or abandoning lawful permanent residency. He served as lead counsel in Aroeste v. United States, the landmark federal case on green card holders, tax treaties, and the exit tax. Best Lawyers in America® (Tax Law), 2015–2025.

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