For tax purposes, they are deemed to have disposed of assets that are not taxable Australian property for their market value.
[4] According to the law "L'impôt sur les plus-values latentes en cas de transfert du domicile fiscal hors de France" Article 167 bis Code général des impôts[5] there is a rule forcing french tax-subjects to pay a tax if they move abroad to certain countries and not return promptly.
[6] Today, when moving out of Germany company shares (ownerships of >1%) will be virtually sold and capital gain taxed based on the current value.
[7] The Netherlands has treaties with Belgium and Portugal permitting them to charge emigration tax against Dutch people who move to those countries.
The aim is to impose a tax on persons who move abroad and cash out on the tax-free appreciation of their Dutch pensions.
A single emigrant may expatriate up to R4 million of assets without exit charge, while a family is entitled to twice that amount.
This applies to departing Spanish resident taxpayers with shares worth more than four million euros or one million if they hold a stake of 25% of a single business and then transfer their habitual residence outside Spain if they have previously lived in Spain 10 of the last 15 years.
The 1966 law created Internal Revenue Code Section 877, which allowed the U.S.-source income of former citizens to be taxed for up to 10 years following the date of their loss of citizenship.
Section 877 was first amended in 1996, at a time when the issue of renunciation of U.S. citizenship for tax purposes was receiving a great deal of public attention; the same attention resulted in the passage of the Reed Amendment, which attempted to prevent former U.S. citizens who renounced citizenship to avoid taxation from obtaining visas, but which was never enforced.
[19] A bill—which failed to advance to the Senate—entitled Tax Collection Responsibility Act of 2007 was introduced during the 110th session of congress in July 2007 by Charles B. Rangel.
Notwithstanding the above, certain dual citizens by birth and certain minors as defined in Section 877A(g)(1)(B) are not considered "covered expatriates."