Can the IRS Exit Tax be retroactive? Does IRC Section 877A go back in time?

Can the IRS Exit Tax be retroactive? Does IRC Section 877A go back in time?

Prior to 2004 a Certificate of Loss of Nationality (CLN) was not needed to renounce ones US citizenship for tax purposes. In 2004, that all changed with a law, Section 877A which now requiresd a CLN There is considerable debate whether or not Section 877A is retroactive in cases where a CLN was not issued. If a the interpretation that 877A is retro-active that would mean many US citizens are missing years of tax returns and foreign reporting. An because they would still be considered US persons, they would need to file Form 8854 and expatriate correctly,y including paying an Exit Tax, if due. One of the top experts, if not the top expert on nationality issues and how they relate the the IRS is John Richardson, Esq. of citizenshipsolutions.ca. John joined host Anthony E. Parent, Esq. of Parent & Parent, LLP a top international tax firm located in Connecticut. With them is Keith Redmond, a global advocate for the American overseas, founder of American Expatriates 2.0 Facebook. The three discuss there conclusions on why 877A is likely NOT retroactive, but why few professionals are willing to say that and give more detail to an article John wrote in 2015 on this subject at Isaac Brock Society https://ift.tt/2E8zaUl Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269 6699 info@irsmedic.com https://ift.tt/1RfwK1f https://youtu.be/xfqRLjYMozQ IRS Medic