Mr. Imhoff, age 72, has lived in Los Angeles his entire life. His net worth is estimated at $95 million. Mr. Imhoff is considering renouncing his U.S. citizenship, selling his home in Los Angeles, and permanently relocating to the Cayman Islands. The Cayman Islands impose no tax of any kind on their residents. Identify the tax issue or issues suggested by the situations, and state issue in the form of a question.