“The media is prone to depict Templeton as a tax cheat. The reason? Had he been a U.S. citizen when he died, the U.S. government would have received approximately 100 million in estate taxes.  I am not aware of Templeton ever publicly stating his reasons for renouncing U.S. citizenship. Nobody knows for sure. But, I suspect that the correlation between his renouncing U.S. citizenship in 1964 and the enactment of the CFC (Controlled Foreign Corporation and SubPart F) rules in 1962 did play a role. The 1962 changes in the Internal Revenue Code meant that Templeton may have been forced to choose between U.S. citizenship and his mutual fund business.”

http://isaacbrocksociety.ca/2013/07/08/why-sir-john-templeton-may-have-renounced-us-citizenship-aka-why-the-us-shot-itself-in-the-foot/

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