FlyerTalk Forums - View Single Post - Price to relinquish US citizenship hiked to match price to renounce US citizenship
Old Sep 25, 2015, 1:27 pm
  #15  
GUWonder
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The IRS does collect deemed tax debts from federal government employees in the way it collects deemed tax debts from non-government employees too. And the IRS collection efforts directed at Al Sharpton are well within the range of what has been allowed to many others when: the IRS lacks confidence about its criminal investigation division being able to get DOJ to win a case on its behalf; or when the IRS isn't sure about the ability to make a timely collection of the debt (in full or even in large part) without running afoul of the kind of items indicated in my words below (following the quote).

Originally Posted by SeriouslyLost
I've wondered at times what the actual UST/IRS policy is on that front. Certain governments outside the US structure things so that it is explicit policy for tax departments to maximize short term revenue - even at the expense of long term revenue and if it destroys companies entirely. New Zealand and Australia, for example, have explicit policies in that direction. I know of instances where they have bankrupted companies to gain overdue taxes owed even when the companies can show they have solid plans and financing in place to survive long term, and repay the tax debts and penalties. The tax authorities would rather get the money now over get the money later, keep people employed, gather penalty payments, etc.
At least in practice, the IRS enters into payment plans/compromises (of formal sorts or otherwise) when and where: the IRS thinks it helps to maximize collection for debts it deems as being due; or the IRS otherwise thinks the debt is either not collectible or collecting (in whole or perhaps even in part) runs contrary to the public interest or reputational interest of the IRS. [The latter part of the latter is to avoid bad publicity such as what would happen if the IRS seized the cancer medicine funds of a cancer-hit child because the child was deemed to have a large IRS debt due.] At least when it comes to individual income tax.

With regard to corporate income tax, it's sort of the same and it sort of is different in practice; and there it may come down to what led to the tax debt, the management circumstances, and some other things.

While bankruptcy can be used to restructure/eliminate tax debts under some very limited circumstances, that doesn't work as well with tax debts as with non-tax debts. Relinquishing or renouncing US citizenship won't help with resolving tax debts already accrued or that become due as a result of provisions applicable to renunciation of citizenship (or of LPR status). Given that foreign resident status tolls the statute of limitations for IRS debt collections, relinquishing or renouncing US citizenship is certainly not an effective way to abscond from paying what the IRS deems to be due to it.
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