If I were to renounce my US citizenship this week, and next week win £5 million in the National Lottery, would I be liable for tax? Obviously not.
If you bought the ticket while a US citizen, you should be. Returns on investments made during citizenship -- and that includes vested ISOs and employee NQs even if they are not exercised while a citizen -- should be included.
Would Americans be upset if Carlos Slim, the richest man in the world, emigrated from Mexico to America and took American citizenship? Would Mexicans be justified in saying that he was evading Mexican taxes?
Yes, probably, but specifically because he's Mexican, for what that's worth. But as for justification: they should be able to keep a hook in earnings made on earnings or assets owned while he was a citizen, because if not, the motive clearly IS evasion.
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Date: 2012-05-21 02:03 pm (UTC)If you bought the ticket while a US citizen, you should be. Returns on investments made during citizenship -- and that includes vested ISOs and employee NQs even if they are not exercised while a citizen -- should be included.
Yes, probably, but specifically because he's Mexican, for what that's worth. But as for justification: they should be able to keep a hook in earnings made on earnings or assets owned while he was a citizen, because if not, the motive clearly IS evasion.