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The exit tax doesn't apply to "gains", it applies to the "value of your company" which is calculated in a way that often means you will owe thousands or even millions in money you don't have, and at no time had.
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Yes - the value of your company is the gain. It is the money you would have if you sold the whole thing.
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It's only a gain if you sell.

Selling a company and paying tax on the profit in tax is a completely different proposition from paying tax on hypothetical profit you haven't made (and might never make) just because you want to move.

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Sounds indeed pretty terrible…
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Most unrealized gains are a notional value, the realizable gains are often much smaller. The act of realization can cause a crash in value.
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