Alan Winston Granwell · Michael J.A. Karlin · Linda Rahal · Rosy Lor · W. Aaron Hawthorne
Renouncing U.S. citizenship or abandoning a green card no longer ends a client's exposure to the U.S. tax system — it shifts the liability forward to the next generation. The §2801 final regulations took effect in 2025, imposing a 40% succession tax on every covered gift or bequest a U.S. beneficiary receives from a covered…