Does renouncing one's US citizenship have the same tax implications as renouncing one's US lawful permanent resident status (i.e., giving up one's green card)?

If that matters (e.g., for tax treaties):

  • The US lawful permanent resident or US citizen is also a French citizen.
  • The individual will keep assets both inside and outside the United States.
  • The individual doesn't know yet whether they'll be working for a US or non-US company, and where they'll physically be located.

https://www.lawyers.com/legal-info/immigration/citizenship/advantages-and-disadvantages-to-u-s-citizenship.html (mirror) claims that:

Once you become a U.S. citizen, it's difficult to ever escape your tax liability to the U.S. government, even if you voluntarily give up your citizenship. A green card holder, on the other hand, can give up his or her green card and not have to worry about filing U.S. tax returns after that.

but it does not give any details.

  • 1
    I believe there's even another layer for green cards. I think it might make a difference for exit tax implications if you actively renounce or the US gov actively revokes it, versus leaving the US and letting it expire and not renewing. – TTT Aug 26 '20 at 22:45
  • @TTT thanks good point, I'm curious about both cases. – Franck Dernoncourt Aug 26 '20 at 22:48
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    I seem to recall that there are special rules regarding income tax for those who renounce their US citizenship for the purpose of avoiding US taxation, and I think the same applies to to those who give up their permanent resident status in the US. – Dilip Sarwate Aug 28 '20 at 12:39
  • The question does not distinguish between giving up citizenship while #1 staying in the country with all assets, #2 moving to another country but working for a US company, and leaving assets in the US, #3 moving to another country and working for a company in that country, but leaving assets in the US, and #4 moving person, employment and assets to another country. Since it's such a huge topic, "Vote To Close - Needs Detail or Clarity". – RonJohn Dec 27 '20 at 6:24
  • @RonJohn I've just added the information you asked to the question. – Franck Dernoncourt Dec 27 '20 at 6:29

Whilz points out an interesting difference:

There will be an exit tax if you relinquish and you were 1) a US citizen, or 2) a long-term resident, which means a green card for 8 or more years in the 15 year period immediately prior to expatriation.

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