In this second half of my conversation with Alexander Marino, Director of U.S. Tax Law at Moody's Tax, we get into the nitty-gritty of what it really means to exit the U.S. tax system, whether you're renouncing citizenship or handing back a long-term green card.

This is one of those areas where emotion, tax policy, and real-life consequences all collide. Alex explains the U.S. exit tax (and how to avoid it), what being a “covered expatriate” actually means, and why some clients are better off paying millions in exit tax now rather than tens of millions in estate tax later. We also discuss some common myths like assuming a high-tax country means you’re covered, or thinking a long-expired green card means you’re off the hook.

The key thing to note here is: this isn’t about being dramatic. For many U.S. expats living in Ireland or abroad, stepping away from the U.S. tax net is a practical financial decision—but it has to be done right. Alex shares how his team helps people navigate this process and why now might be the best window in history for high-net-worth individuals to consider it.

If you’re feeling stuck or unsure about your U.S. status, don’t put it in the “too hard” basket. As always, professional advice is essential but hopefully this episode gives you a strong foundation to start asking the right questions.

This is Part 2 of a two-part conversation with Alexander Marino. For Part 1, make sure you subscribed to the podcast.

Main Topics discussed in this Episode:

1. Understanding the U.S. Exit Tax: We unpack how the U.S. exit tax works and why avoiding it comes down to good planning, not good luck.
2. Covered Expatriate Rules: Alex explains what makes someone a “covered expatriate” and the costly consequences that can follow.
3. Green Card Holders Are Not Off the Hook: Letting a green card expire doesn’t end your U.S. tax obligations—many are surprised to learn they’re still on the hook.
4. When Tax Treaties Don’t Protect You: Tax treaties help avoid double tax, but they offer no protection when only the U.S. taxes an event.
5. Why Now May Be the Smartest Time to Act: Current exemption levels make this an unusually favourable moment to plan an exit from the U.S. tax system.

Get in touch with Alex Marino:

Email: [email protected]

Website: https://moodysprivateclient.com/team/marino-alexander/

LinkedIn: https://www.linkedin.com/in/alexander-marino-45a76b26/

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Taxbytes for Expats is brought to you by ExpatTaxes.ie. If you're considering moving to or from Ireland and would like support with your taxes, book a consultation today: https://expattaxes.ie/services-and-pricing/.

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