Renouncing Citizenship to Avoid Taxes
There was news in recent days that one of the co-founders of Facebook (Eduardo Savarin) has renounced his U.S. citizenship to avoid paying a hefty tax bill (approximately $600 million) when the company goes public this week. I’m ignorant of the law on this point, but are there really no restrictions on the right to relinquish citizenship on a date of your choosing? If there are equitable limitations, this would seem like a good time to invoke them and say that he cannot opportunistically avoid taxes in this way. If there are no such limits, I wonder if the Government will consider exercising its discretion to deny him entry into the United States from now on.