Apart from FATCA, there is also the Expatriation Tax, introduced after Facebook cofounder Eduardo Saverin took his money out of the country by renouncing citizenship [0,1,2]. This often referred to as Exit Tax.
It also applies to Greencard holders for more then 8 years, defined as long term permanent residents.
The Exit Tax is a huge tax penalty (37%) on anyone owning more than $2 million [3].
Is that right? From reading the third document you linked:
"IRC 877A imposes a mark-to-market regime, which generally means that all property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date."
Unless this document is leaving something out, the gains would not be taxed at the marginal income rate unless they are short term gains. Presumably most people with large amounts of unrealized gains would be paying long term capital gains taxes, which are currently a 20% rate.
I thought this provision was simply to ensure that you didn't make large amounts of wealth in the US then skip out on paying taxes on your gains. That seems very reasonable to me, although perhaps I am missing something.
"IRC 877A imposes a mark-to-market regime, which generally means that all property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date."
Unless this document is leaving something out, the gains would not be taxed at the marginal income rate unless they are short term gains. Presumably most people with large amounts of unrealized gains would be paying long term capital gains taxes, which are currently a 20% rate.
I thought this provision was simply to ensure that you didn't make large amounts of wealth in the US then skip out on paying taxes on your gains. That seems very reasonable to me, although perhaps I am missing something.