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Old 03.02.2020, 14:00
Caryl Caryl is offline
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Re: Looking for lawyer - US nationality law

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Hi, thanks for the reply.

The question is one of renunciation of US citizenship for a Swiss national.

We already have legal counsel in the US and a lot of research done already but would also like to explore the possibility of a more easily-contactable lawyer based in Switzerland, perhaps also with specialist knowledge regarding Swiss matters on this.
I think I can answer any questions you are likely to ask. I am retired from the practice of (nationality, tax and bankruptcy) law and take no new clients. I have a few points:

(1) I discourage enquirers from retaining the most Internet-public US counsel except for John Richardson whose fees are low and who has a realistic (in my view) appraisal of the (non-)need for US tax compliance for a good many renunciants

(2) From the Swiss standpoint an issue is conflict with certain pre-renunciation US assets, particularly trusts and some pensions. Also estate planning and family gifting, the lack of any comparable asset title such as RLTs (revocable living trusts) and TOD (transfer on death) accounts. There may also be some issues with Social Security and pensions but the Totalization Agreement and the Tax Treaty deal with all except one wrinkle: US military pensions may be forfeit upon renunciation.

For the rest, as others have said, I don't see a problem. But it's worth noting that investment opportunities are less in Switzerland, and fees considerably higher. But you are free from FATCA and potential double taxation. (If you own a U.S. entity, be aware of the draconian ($25,000) penalty for not filing IRAS Form 5472.)
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