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Expatriates surrendering their citizenship will have to act as if they have sold all their worldwide assets at a fair market price. If the unrealized gains on these assets exceed $600,000, capital-gains tax will apply. Along with citizens of North Korea and a few other countries, Americans are taxed based on their citizenship, rather than domicile.

In Hong Kong the temptation for Americans to switch citizenship is particularly strong, because of the territory's low taxes. On the other hand, banks and other firms who want to hire Americans may find it harder to do so, even though greater China is one of the world's fastest-growing regions. It places Americans in the awkward position of weighing their patriotism against their vocation.