The Final State of Expatriation? - Part II

There are many issues that need to be addressed in public guidance under the expatriation tax provisions of the HEART Act. After a hiatus of some months, Treasury and the IRS are believed to again be working on a substantial notice that is intended to fill in many of the gaps left by the statute. However, to date, the only guidance that has issued regarding the new law is found in the substantially revised Form 8854 that was published at the end of May 2009 and the new Form W-8CE that appeared at the end of April 2009. Click here to read the full version of the article.