Inevitably there are tax issues on the way out

Warner Bros. kick-started a so-so domestic run Thursday at midnight for Tim Burton's Johnny Depp starrer ''Dark Shadows,'' which collected an estimated $550,000 from approximately 1,600 late-night locations. The PG-13-rated ''Dark Shadows'' was cheap louis vuitton sunglasses projected as of yesterday afternoon to hit in the mid-$30 million range through Sunday, with a potential $40 million upside. Midnights would suggest a bow closer to the former. For comparison, last summer's ''Cowboys and Aliens'' grossed $800,000 in midnights and wound up earning $36 million during its opening weekend. ''Super 8,'' which debuted to $35 million last June, earned $500,000 from midnights. Rarely do midnight grosses tell the whole story, however. ''Dark Shadows'' is tracking best with women over-25, who typically are not first-responders. The film's midnight start also does not account for word-of-mouth building throughout the weekend, though ''Shadows'' has received mostly mixed reviews. Overseas, ''Dark Shadows'' got off to a strong start, particularly in France, where the pic ranked No. 1 on Wednesday with $770,000 -- 19% ahead of the local opening-day gross for ''Sweeney Todd.'' ''Dark Shadows'' bows this weekend in a total 42 offshore markets; pic's Stateside rollout includes 3,755 locations. More? Rates, complexity, worldwide reporting, and louis vuitton hoodie comprehensive–some say downright intrusive–disclosure. Facebook’s Mark Zuckerberg—with or without signature hoodie—may get all the hype in the romping roadshow run-up to the company’s historic IPO. Most of us are agog that Mr. Zuckerberg may be poised to pay the highest individual tax bill ever. See Top Tax Tips From Zuckerberg’s Facebook Bonanza. But the latest news-grabbing Facebook co-founder is Eduardo Saverin, best known for his bitter legal battle with Mr. Zuckerberg. In The Social Network, we saw Mr. Zuckerberg’s Jesse Eisenberg outsmart Saverin and the Winklevoss twins to make Facebook, Harvard, Internet, and Wall Street history. In Hollywood’s version, maybe Mr. Saverin came off as wimpy but he may get the last laugh, especially when it comes to taxes. As Mr. Zuckerberg prepares to pay over a billion in taxes, Mr. Saverin renounced his U.S. citizenship ahead of the company’s IPO. In fact, it turns out he did it a good deal ahead of the IPO, and that’s likely to matter. This is actually old news, dating to September 30, 2011 when the IPO was a pipedream. But the information didn’t become public until Bloomberg reported that the IRS released his name on April 30. Born and raised in Brazil before moving to the U.S. in 1992, the 30-year old Mr. Saverin now lives in Singapore. It is unimaginable that U.S. taxes were not a huge part of his decision, since “taxpatriations” are now all the rage. See Celebrity Leavings: Bidding Stars Adieu. And that is perfectly legal. Tax avoidance intent when expatriating used to trigger tougher tax rules, but burberry handbags that changed in 2008. Tax motivation is no longer even relevant to the tax treatment of citizens or permanent residents who permanently depart the U.S. See Ten Facts About Tax Expatriation. Inevitably there are tax issues on the way out. See Ten Facts About Tax Expatriation. U.S. citizens or long-term residents who expatriate after June 16, 2008 are treated as having sold all their worldwide property for its fair market value the day before leaving the U.S. Although taxed as a capital gain, this “exit tax” is unforgiving. See Rich Americans Voting With Their Feet To Escape Obama Tax Oppression. Fortunately, only “covered expatriates” face the exit tax. Some people born with dual citizenship are exempt but must still file an IRS Form 8854, Initial and Annual Expatriation Statement. More generally, you can escape the exit tax if you have less than $651,000 of income from the deemed sale of your assets, adjusted for inflation. As you might expect, appraisals of property are a good idea. See Fancy Appraisals Can Defeat IRS. Even if you owe the exit tax, you may apply to defer it by filing IRS Form 8854 (in some cases for ten years). Additional forms may be required if you have deferred compensation, tax deferred accounts, certain non-grantor trusts, etc. A good resource is Notice 2009-85. As for Mr. Saverin, the value of his holdings burberry belts on sale as of September 30, 2011 was probably a pittance compared with today’s figure. For someone with appreciating assets not tied irrevocably to the U.S., taxpatriation may simply be too tempting to pass up.