Suppose changes to the GV require us to abandon it or become tax resident. What are the consequences of tax residency if we are eligible for NHR?
For example I believe normal PT tax residents who break tax residency (by moving away) still have to pay an exit tax on all appreciated assets, effectively capital gains tax as if all assets were sold at the moment they broke tax residency.
For many people in a position to afford a GV, this could be a significant tax bill.
Does NHR protect one from this kind of exit tax?
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This is a very interesting question, I’m not an expert, but perhaps if one is intending to ‘exit’ PT then it’s not best to bring assets onshore (ie into PT) but keep them in a jurisdiction with a DTT with PT that doesn’t levy CGT on non-resident persons. I believe this would avoid a PT ‘exit’ event.
Interested in our people’s thoughs…
This was my first thought, especially as a US citizen who will be getting taxed anyway. Leave as much as possible “in” the US.
But I am definitely not a tax pro, so do not listen to me!