If I’m understanding this correctly, Cole V. Commissioner argued this and the courts found that the expatriate had to pay taxes:
As a result of moving to Israel, petitioner qualifies for a 10-year Israeli “tax holiday”, which exempts him from Israeli tax on non-Israeli-source capital gain income… we hold that petitioner must recognize total long-term capital gain of $114,947 attributable to his sale of Neogen stock in 2010
I am not sure this I am interpreting this correctly, and would love to hear input from others.
Edit: I spoke to an Israeli tax lawyer who confirmed my understanding, though he said to double check with a US lawyer to be sure.
If I’m understanding this correctly, Cole V. Commissioner argued this and the courts found that the expatriate had to pay taxes:
I am not sure this I am interpreting this correctly, and would love to hear input from others.
Edit: I spoke to an Israeli tax lawyer who confirmed my understanding, though he said to double check with a US lawyer to be sure.