PPLI and Exit Tax Planning for Expatriation

Offshore Tax with HTJ.tax · Jun 16, 2026 · 2m

For wealthy Americans considering expatriation, one of the most significant tax hurdles is the:👉 U.S. Exit TaxUnder the expatriation rules, certain individuals are treated as having sold their worldwide assets immediately before renouncing U.S. citizenship or long-term permanent residency.This deemed sale can trigger substantial tax liabilities—even when no actual sale occurs.As a result, sophisticated expatriation planning often focuses on minimizing exposure to the mark-to-market regime.⚖️ 1️⃣ What Is the Exit Tax?Under the expatriation provisions of the:Internal Revenue Code §877Acertain…