The FBI has released its latest report on Active Records in the NICS Index, updated to 31 March 2013. NICS now contains the records of 21,504 persons who are prohibited from purchasing firearms in the United States because they swore an Oath of Renunciation of United States Citizenship at a U.S. consulate abroad. This is an increase of 196 records as compared to 28 February, and 850 records in the first quarter of 2013 (since 31 December 2012). The quarterly number of renunciants shows an increase of 88% as compared to the same period last year — as we reported two months ago, 452 records of renunciants were added to NICS in the first three months of 2012.
However, the number of renunciants has declined since the third and fourth quarters of 2012, which showed an average of 1,744 people renouncing (a breakdown for each quarter is not available because the FBI did not issue a NICS report for the month of September, meaning the October figure listed in the table represents an increase for two months, straddling the boundary of the third and fourth quarters).
Assuming that the number of renunciants reported by the FBI is accurate, the next question to ask in analysing this data is whether we expect that the number of renunciants should show a seasonal trend or not; that is to say, should we be comparing to the same quarter in the previous year, or the previous quarter. This is hard to tell from the existing data — we only have monthly NICS renunciation data going back for less than two years, and while we have more than a decade-and-a-half of IRS “published expatriate” data, analysing it for seasonal trends is difficult because the delay in the publication of names is large and not-well-understood — some people show up in the Federal Register within a couple of months, while others take more than a year, and the delay itself may change from year to year.
Some drivers of renunciation are distributed essentially randomly throughout the year — election candidacy dates for public offices or admissions dates to military officer training schools in roughly 200 countries and territories on the planet. But one big driver has a very obvious seasonal component: if you want to avoid being subject to onerous U.S. financial reporting requirements for yet another 1040 & FBAR filing season, you have to commit an “expatriating act” before 31 December. And of course, as those reporting requirements become more onerous, we wouldn’t expect to see a decrease in the number of people renouncing citizenship going forwards. (Incidentally, if the trend is seasonal and the number of renunciants for each of the coming quarters is also 88% higher than the same period in the previous year, that — along with the five or six-to-four ratio of renunciants to relinquishers — would suggest that about fifteen thousand people will give up U.S. citizenship this year.)
But all of this is just speculation and back-of-the-envelope calculations. When it comes to a set of suspicious and hard-to-understand numbers, it’s always better to have more eyes and more minds than fewer, but mainstream media attention to this story has been almost entirely absent. Major newspapers and the lawyers they quote continue to show no awareness of the FBI’s NICS data, and so they theorise based solely on the IRS data that “most of the individuals who have decided that their U.S. citizenship is not worth the cost of continuing to file U.S. tax returns have already renounced their citizenship”. So far, only Advisor.ca — published by Rogers Media of Canada — has written a story about the discrepancy between the FBI and IRS data on loss of citizenship.
Anyway, it will be quite interesting to see how many of these renunciations the Federal Register will admit to when Ann Gaudelli over at the IRS gets around to publishing it next month or later.