[Editor’s note: This post clears up the issue of whether 8854 is required for people receiving backdated CLNs: If your expatriation date is before 2004, the rules are different]
(This comment from yesterday, buried at the end of an ancient thread, may have gotten lost in the perpetual flurry. So I repeat it here as a posting in its own right.)
Nobody has yet convinced me that any person who now relinquishes or renounces is not required to file Form 8854 to satisfy the IRS.
This official document says that 8854 applies to anyone expatriating after 16 June 2008.
And this official document says at 2.A — unless I can’t read — that for practically all of the Brock crew, unless you have already done the US consulate thing, you have not expatriated yet. Backdate that precious CLN to 1776 if you want, but when did you actually visit the US consulate?
Principle Number One: Department-of-State and Department-of-Treasury/IRS are weird and separate fiefdoms — and you are a serf to both. The best path to escape from those overlapping dark dominions seems a murky mystery.
Is there any chance we could get informed opinion on the Form 8854 requirement — rather than heartfelt assertion, raw speculation, desperate hope, wild wish, etc etc etc?
At the least, I’d love to see two “professionals” come up with diametrically opposed views. That couldn’t possibly happen, could it?
New Addendum: Counterexample is the cornerstone of scientific validation, aka hypothesis disproof. Today 13 June 2012 at Brock we have the wonderful and extremely valuable reporting from freeatlast: that the Federal Register name-and-shame list is not limited to “covered” expatriations. One more goofy speculation laid to rest.