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Expatriation tax


An expatriation tax or emigration tax is a tax on persons who cease to be tax resident in a country. This often takes the form of a capital gains tax against unrealised gain attributable to the period in which the taxpayer was a tax resident of the country in question. In most cases, expatriation tax is assessed upon change of domicile or habitual residence; in the United States, which is one of only two countries (Eritrea is the other) to tax its overseas citizens, the tax is applied upon renunciation of citizenship on top of all taxes previously paid.

Canada imposes a "departure tax" on those who cease to be tax resident in Canada. The departure tax is a tax on the capital gains which would have arisen if the emigrant had sold assets after leaving Canada ("deemed disposition"), subject to exceptions. However, in Canada, unlike the U.S., the capital gain is generally based on the difference between the market value on the date of arrival in Canada (or later acquisition) and the market value on the date of departure.

In December 1931, the Reich Flight Tax was implemented as part of a larger emergency decree with the goal of stemming capital flight during the unstable Interbellum period. After the Nazis seized power in 1933, the Nazi government largely used the tax to confiscate assets from persecuted people (mostly Jews) who sought to flee the Third Reich. This tax was officially repealed in 1953.

The Netherlands has treaties with Belgium and Portugal permitting them to charge emigration tax against Dutch people who move to those countries. The aim is to impose a tax on persons who move abroad and cash out on the tax-free appreciation of their Dutch pensions. However, in 2009, the Supreme Court of the Netherlands ruled that the Tax and Customs Administration could not impose an emigration tax on a Dutch man who moved to France in 2001.


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