Citizens and green card holders who think about exiting the US are probably aware of the expatriation tax at exit. Most assets are deemed sold and taxed accordingly. However, the tax at exit does not end a covered expatriate's relationship with the IRS. The expatriation tax regime in fact includes gift and estate tax components that follow a covered expatriate for life and then after death, perhaps long after death.
These components apply to covered expatriates regardless of their previous gifting history and regardless of their net worth at death. In tax lingo, there is no lifetime gift tax exemption amount, nor is there an applicable exemption amount. US taxpayers who would never have to pay US gift or estate (inheritance) taxes may be subject to both if they expatriate.