Immigration Law Considerations, Lawful Permanent Residents, Tax Policy

“Expatriation” Implies Leaving the U.S., But Many More Want to Come to the U.S.: Tax Consequences

By · July 16, 2015 · Updated June 3, 2026

U.S. citizens and long-term residents who are considering renouncing their citizenship or abandoning their lawful permanent residency (“LPR”) are increasingly undertaking more sophisticated life and tax planning before “taking the plunge”!

Many (in my experience – all) of these “expatriates” eventually want to be able to visit the U.S. and in some cases possibly come back to live permanently.  Many simply apply for and obtain a B1/B2 visa.

To appreciate how many more persons want to immigrate to the U.S. compared to emmigrate from it, see an earlier post:  The Number of Citizens Leaving (Renouncing) Versus Coming (Naturalizing) is Just a Speckworld-map.png

This is the other “side of the coin” so to speak, since individuals contemplating coming to the U.S. often should undertake pre-immigration tax planning.  One means for non-U.S. citizens to become LPRs and eventually U.S. citizens, is through the EB-5 visa program.

Immigration attorney Ms. Teodora Purcell has written prior guest posts, including:  When is the loss of US nationality effective? [Guest Post from Immigration Lawyer]

The next post on this site will be a complete article by Ms. Teodora Purcell explaining in more detail the EB-5 visa program and recent developments.

As to the tax implications of immigration to the U.S. (as opposed to emigration from it), I wrote the tax chapter in the latest edition of the American Immigration Lawyers Association (“AILA’s) treatise –  Immigration Options for Investors & Entrepreneurs US$199.

That treatise is heavily focused on “EB-5 investors”  and the tax discussion is titled:  Key U.S. Tax Considerations for EB-5 (& Other) Visa Applicants.

Ms. Teodora Purcell’s contact information is set out below:

Teodora Purcell | Attorney at Law
FRAGOMAN

11238 El Camino Real, Suite 100, San Diego, CA 92130, USA
Direct: +1 (858) 793-1600 ext. 52424 | Fax: +1 (858) 793-1600
TPurcell@Fragomen.com

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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