On January 9, 2009, Michael Karlin appeared on the panel, “Expatriate Games: New Sections 877A and 2801,” for the ABA Section of Taxation Committee on U.S. Activities of Foreigners and Tax Treaties in New Orleans. The discussion dives into the nuances of Section 877A including classifications of “covered expatriates” as they relate to market-to-market regime rules, exit taxes, deferred taxes, adjustments, valuations, treaty interactions, and subsequent exceptions. Along with this, the panel explores the nuances and issues associated with Section 2801 which governs the new succession tax. The Senate Finance Commitee’s Joshua Odintz, IRS’ Benedetta A. Kissel and Willard W. Yates, Caplin & Drysdale’s Michael G. Pfeifer, and Holland & Knight LLP’s Summer A. LePree also appeared on the panel.
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