“The 2008 amendments levy an ‘exit tax’ applies to both U.S. citizens and long-term U.S. residents—green card holders who have resided in the United States for at least eight of the 15 years prior to expatriation. The tax is predicated on the legal fiction that you sell all of your worldwide property at its fair market value on the day before you expatriate. But that’s only the beginning. In 1996, Congress enacted the ‘Reed Amendment’ to the Immigration and Nationality Act. The amendment gives the US Attorney General the discretion to deny entry into the United States to a former US citizen who renounced US citizenship in order to avoid US taxation.”
http://www.nestmann.com/homelanders-to-u-s-expatriates-dont-come-back-ever/
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