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Also, given the exit tax, he'll have to pay taxes on them as if he had sold the properties, despite the properties not having been sold.


My reading of the exit tax is it is merely paying all the taxes on any gains that you have made but have yet to pay. For example if you have bought stock but not sold it you would be taxed on the gains you made. This applies to real-estate and other holdings as well.

To me this makes sense it is like you paying your final taxes before leaving as such I don't see how it is anything additional but I could very well be mistaken.




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