CAN U.S. EXPATRIATES BE BARRED FROM THE U.S.?
Most tax practitioners have been very aware of the recent focus that U.S. legislators have given to “taxpatriates”, U.S. citizens who are expatriating for tax purposes. Various roadblocks were proposed with some actually implemented. However there appears to have been a great deal of confusion in the popular press about an immigration law in this area. Headlines such as “And dont come back” (Forbes Nov. 18,1996) and “Your papers please!” (Forbes June 16,1997) give the impression that taxpatriates will somehow uniformly not be able to visit the U.S. in the future. This is far from true, but this type of false propaganda has served to scare off the misinformed from what has been and still remains to be an excellent tax and asset protection strategy. In order to understand where the confusion lies, it is worth looking at the immigration provision in question. In September 1996, as part of a larger immigration bill, the U.S. Congress created a new ground of potential exclusion for any “for