¹ See Sec. 2010(c); for a discussion, see Sawyers and Satchit, “Significant Recent Developments in Estate Planning,” p. 540, this issue.

² See Richard L. Doernberg, International Taxation in a Nutshell (West Group, 5th ed., 2001), 5.

³ See Sec. 7701.

⁴ See Joint Committee on Taxation, Review of the Present-Law Tax and Immigration Treatment of Relinquishment of Citizenship and Termination of Long-Term Residency, JCS-2-03 (February 2003).

⁵ Rev. Rul. 80-363, 1980-2 CB 376.

⁶ Rev. Rul. 80-209, 1980-2 CB 248.

⁷ See Sec. 2001(c).

⁸ See H Rep’t No. 100-795, 100th Cong., 2d Sess. (1988), p. 592.

⁹ See Est. of Edouard Paquette, TC Memo 1983-571.

¹⁰ See Godfrey, “The Phaseout of the Federal State Death Tax Credit,” Part I, 35 The Tax Adviser 96 (February 2004) and Part II, 35 The Tax Adviser 148 (March 2004).

¹¹ See Income Tax Rates Act 1986, Schedule 11.

¹² See U.S. Citizenship and Immigration Services, “I am a Permanent Resident…How Do I…Apply for U.S. Citizenship?” at www.uscis.gov/graphics/services/factsheet/howdoi/B3.pdf.

¹³ See Osborne and Schurig, Asset Protection: Domestic and International Law and Tactics (Clark Boardman Callaghan, 2006), Vol. 2, 24:20.

¹⁴ See Regs. Sec. 301.6114-1(d).

¹⁵ See Finance Act, 1986, Section 100.

¹⁶ See Convention Between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Estates of Deceased Persons and on Gifts (signed 10/19/78), Article 9.