Pre-immigration tax planning is focused on current nonresident individuals who, as a result of anticipated changes in their American immigration status, will become United States taxpayers. It is absolutely critical to implement proper planning during the pre-residency period – both for income tax purposes and estate and gift tax purposes. Planning focuses on income acceleration and basis step-ups for foreign-sitused assets – with millions in prospective American tax very often able to be saved.
For current United States taxpayers prospectively becoming nonresidents, planning often centers around “exit tax” ramifications. United States citizens and long-term green card holders can be subject to exit tax – which carries both income tax consequences upon exit and potential inheritance tax issues for United States beneficiaries.