You may have noticed an increase in US citizen clients who want to officially leave the United States. They do so for a variety of reasons, including dissatisfaction with the political climate and economic trends, as well as to pursue international opportunities. But as Joan K. Crain notes in her article, “Expatriation: Look Before You Leap!” page 46, many American citizens and their advisors are unaware of the challenges that arise when ties with the United States are severed. Her article goes on to explain how practitioners can help clients navigate these complex waters and mitigate future liabilities.

The complexities of expatriation are not the only challenges facing internationally focused clients. Another is the high penalties for not reporting foreign accounts through Foreign Bank and Financial Accounts (FBAR). Until recently, courts were less open to arguments challenging these convictions. However, several court decisions (including one from the US Supreme Court) indicate a change in the legal landscape. For example, the Court in Bittner v. United States stated that according to the Bank Secrecy Act, a taxpayer's failure to file a compliant FBAR should be treated as one violation—not as a separate violation for each foreign account that is not reported on time. “Changing Currents in FBAR Penalties”, p. 68, by Rita M. Ryan reviews these court decisions.

Those practitioners who advise clients based in the United States have their own issues to contend with, one of which is the impending demise of the estate and gift tax exemption. In his article, “Racing Off Into the Sunset,” p. 28, Stephen L. Ham IV explores the need to make delayed generation pass transfer tax (GST) allocations to non-exempt or partially GST-exempt trusts before sunset.