Authored by: Steven A. Richman Eduardo Savarin, one of Facebook’s co-founders, recently announced that he renounced his U.S. citizenship in September of 2011, several months in advance of Facebook’s initial public offering (“IPO”).  The resulting tax consequences (not to mention the political fallout from Washington) offer an interesting case study into the Internal Revenue Code’s expatriation rules, which are covered in Section 877A. Per Section 877A, individuals who are “covered expatriates” are treated as selling all of their assets for their fair market value (e.g., mark-to-market) upon their expatriation (thereby triggering income tax on any built-in-gain), even if they don’t… Read more