Would this be illegal? (involves citizenship renunciation)

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Hi there.

Someone I know is a USA citizen but working abroad. He wants to renounce his citizenship.

He is working in partnership with someone, and forming a limited company.

Rather than registering to own 50% of the company now, he wants to work for the company for free for the first several months, and then buy the shares off of the other partner at a later date, in order to be tax effective.

Is this a legitimate action or would this be looked upon as illegal tax evasion?
 

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