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56 Ateneo L.J. 1 (2011-2012)

handle is hein.journals/ateno56 and id is 1 raw text is: Expatriates and Retirees Coming to the Philippines: Giving Up U.S. Citizenship and the U.S. Exit Tax Robert L. Wolff* Anthony Edsel C. Tupaz** I. INTRODUCTION. .................................... ........ I II. OVERVIEW OF THE FBAR RULES ...........9.............9 A. Persons Subject to FBAR B. The Financial Account Must be in a Foreign Account C. The Financial Interest of a U.S. Person Needed for FBAR D. Value of the Account E. Potential Penalties F. Amnesty III. THE HIRE ACT AND THE NEW FATCA RULES... ..............20 A. Increased Disclosure Under FATCA B Financial Institution Disclosure C. Penalties D. Expanded Statute of Limitations E. Foreign Targeted Obligations F. Reporting Rule for PFICs IV. FORM 3520 DISCLOSURE REQUIREMENTS. ................... 27 V. THINKING ABOUT GIVING UP U.S. CITIZENSHIP TO AVOID TAX ISSUES ...............................................29 A. Overview of a Covered Expatriate B. The Mark-to-Market Exit Tax and the Inheritance Tax C. The Reed Amendment VI. PLANNING CONSIDERATIONS ............... ................35 VII.CONCLUSION .............................................39 I. INTRODUCTION Travelers move in more than one direction. While many people around the world are trying to get into the United States (U.S.), either legally or illegally, there are many others on their way out.' Individuals planning to * 'oo L.L.M., Georgetown Law Center; 'oo J.D., Albany Law School. The Author is a member of the law firm of Robert L. Wolff He was admitted to Digitized from Best Copy Available

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