[lavaroise]

If she's shifted income and assets out of her name to protect them from seizure, they could nail her for fraudulent transfer.

hmmm, choosing a place of foreign living is voluntary and thus paying taxes, in a theoreticaly free world is a voluntary choice of place where you want to live... of course one should give up US citizenship in that case.. which means that it would be more an INS case rather than an IRS case.

[1rudeboy]

You cannot renounce citizenship in order to avoid paying taxes. If you do, the IRS will keep you on-the-hook for a number of years.

[Jack Black]

If you give up US citizenship to avoid paying taxes you are still liable for them. Ted Kennedy got this passed a few years ago. He was outraged that some rich people were renouncing their citizenship and moving to tax havens. If the IRS determines you have moved primarily to avoid taxes they will send you a bill. They may not have much luck collecting it if you are in the Cayman islands, but they could make it very unpleasant to visit old friends in the USA.