Basically what the HEART taxation act means for foreign citizens on greencards is that if we stay longer than 8 years that the USA government wants to tax our income our entire net worth, even money you might have earned 10-20 years BEFORE you even moved to the USA :(
I'm sure that the politicians who passed this knew what they were doing but anyone who employs foreign nationals to provide valuable services for their companies may not understand why people are going to be turning down good jobs to leave the USA before they reach the 8 year limit.
This is going to be a major major problem for USA companies and a brain drain on valuable skill sets.
If you are a foreign national holding a greencard what do you think about this?
If you an employer who has green card staff on your payroll what do you think about this and how are you planning to handle staff leaving your company to go back home (or more likely move to more favourable tax jurisdictions).
BTW can you believe the irony that fat slob Charlie "tax cheating" Rangel was the author of this bill that is going to drive expats away from the USA, lol bet you the NY Times never prints the irony of that one.
P.S. A couple of worthwhile links to check out;
Explanation of $651,000 capital gains threshold - https://www.forbes.com/sites/robertwood/2012/12/01/high-cost-to-go-green-giving-up-a-green-card/#532ef010c08c
One of the best explanations of the entire S. 877A IRS Tax code situation from the view of a Canadian giving up USA citizenship (same position applies to most people having to pay Heart Taxation Act "USA Exit Tax") explains the calculations and implications over 9 different articles - http://www.citizenshipsolutions.ca/2015/04/01/renouncing-us-citizenship-how-the-s-877a-exit-tax-may-apply-to-your-canadian-assets-5-parts/