Relinquishing domestic residence could lead to significant tax liability for shareholders of small and medium-sized businesses - even without selling their shares. How come? Under Section 6 of the Foreign Tax Act, such change of residence is treated as a sale of the shares (and taxation of the built-in gains) if certain minimum ownership requirements are met. Here is some information as to the current requirements, the key restrictions and changes in the statute, but nevertheless also some opportunities for taxpayers.
