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Will U.S. Tax Law Regarding “Covered Expatriates” get Modified with Recent Government Push in International?
By Patrick W. Martin
· May 11, 2016 · Updated June 3, 2026
It is rare to have the President of the United States hold press conferences specifically dealing with international tax policy and tax enforcement. Nevertheless, this is what happened last week when President Obama announced his administration’s recent efforts in the field of international tax, anti-corruption and financial transparency.
His remarks can be watched here: President Obama’s Efforts on Financial Transparency and Anti-Corruption: What You Need to Know
Also, the White House is putting forward a series of initiatives in this area:
Fact Sheet: Obama Administration Announces Steps to Strengthen Financial Transparency, and Combat Money Laundering, Corruption, and Tax Evasion
To date, none of the specific initiatives address current “tax expatriation law” under IRC Sections 877, 877A, et. seq.
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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