As reports flood in from stalwart Brockers — CLNs arrive for Peg11 and recalcitrantexpat, Don Pomodoro gets a second appointment and renounces — and advanced backstories trickle in from lurkers and indirect reporters, it is still the case that almost all are still somewhere in the middle. Few share the absolute closure of schubert1975.
In broad terms, these are the stages of U.S. personhood for extraterritorials:
• Realizing that U.S. personhood is problematic
• Assessing the options and current conditions
• Deciding to act now or to sit tight
• If acting, engaging in some combination of attempting to become compliant /
maintaining or enhancing compliance / seeking exit
• Monitoring an ever-changing situation to gauge position in the middle
• Pondering the subroutines and timelines of exit: consulates, appointments,
relinquishment/renunciation, receipt of CLN
• Seeking to log out of the system without encountering a fatal error: 1040+1040NR
and 8854 and FBAR, unless confident with backdated CLN
• Dealing with detritus and fallout (eg, ITIN vs SSN, Social Security)
Plaudits to Michael J. Miller for his recent provision of informed clarifications on Form 8854, even if certain margins of uncertainty cannot be dispelled.
The front edge of a pioneer wave seems now to be heading into the later items on the list — the aftermath of CLN.
A recent question on the relationship and timing of ITIN superseding defunct SSN has fallen off the plate, but deserves a good answer. For example, at what point after renunciation does SSN “go dead,” and at what point can ITIN be sought? Back to that crazy limbo of having renounced but not having a CLN in hand.
Phil Hodgen talks about logging out of the system properly, and the broad outlines are clear. Read the form and instructions for the multimultipurpose 1040NR, and see that the application to expatriation is as clear as mud — compounded by relationship to that other real return which is for one whole year, not two partial years. Even an ordinary dual-filing accountant is unlikely to penetrate that gobbledygook with assurance.
The other middle that applies to everybody, no matter what they’re doing or not doing, is — as schubert1975 perceptively pointed out earlier today — the utter uncertainty about what comes after the November U.S. election, and how the changes that follow may affect those swimming midstream in the river they can see now, those who are not even sure how far they will manage to have swum through the opacity by that point.
Emblematic of that inability to assess circumstances is Don Pomodoro’s feeling moved to ruminate, on the very day of his renunciation, that conditions just might change, to render that renunciation unnecessary.
The United States is a headless chicken that has become the marvel of the barnyard.