Expatriate Tax Maze (Part 3): The US Expatriation Tax & Covered Expatriate Rules episode artwork

EPISODE · May 29, 2026 · 9 MIN

Expatriate Tax Maze (Part 3): The US Expatriation Tax & Covered Expatriate Rules

from Beyond Accounting Bitesize · host Breiffni O Domhnaill

Giving up US citizenship or handing back a long-held green card sounds like a clean break — but the US tax system has other ideas. Since the HEART Act of 2008, expatriating Americans and long-term green card holders can be hit with a mark-to-market exit tax that treats nearly everything they own as if it had been sold the day before departure.In part 3 of Navigating the Expatriate Tax Maze, Dave Zydek and Peter Trieu of BDO unpack:Who counts as a "covered expatriate" — and the three tests that pull you into the regime (tax liability, net worth, and certification)Who qualifies as a long-term green card holder (the 7-year rule)What the mark-to-market exit tax actually looks like in practiceThe 30% tax on future distributions from non-grantor trusts to former covered expatriatesThe 40% inheritance-style tax on US persons receiving gifts or bequests from covered expatriatesPlanning moves to avoid covered expatriate status — including primary residence sales, lifetime gifting, and spousal transfersEssential listening for anyone considering expatriation or advising clients who are.Brought to you by CAW Network USA in partnership with BDO.

Episode metadata supplied by the publisher feed · Published May 29, 2026

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Giving up US citizenship or handing back a long-held green card sounds like a clean break — but the US tax system has other ideas. Since the HEART Act of 2008, expatriating Americans and long-term green card holders can be hit with a mark-to-market exit tax that treats nearly everything they own as if it had been sold the day before departure. In part 3 of Navigating the Expatriate Tax Maze, Dave Zydek and Peter Trieu of BDO unpack: Who counts as a "covered expatriate" — and the three tests t...

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Expatriate Tax Maze (Part 3): The US Expatriation Tax & Covered Expatriate Rules

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