I am making a post of this comment by Muzzled No More.
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Could I suggest that Brockers make comments at the following link.
http://www.regulations.gov/#!documentDetail;D=DOS_FRDOC_0001-2956
Comments on the fee-hikes for consular services are being accepted until Oct. 21.
I am unable to do so (still Muzzled in some regards) but if I could, my comment would be as follows:
“It is every American’s constitutional right to renounce his citizenship. As a right, renunciation of citizenship should be free of charge or, at worst, available at an extremely nominal fee, certainly no higher than the “user-pay” fee one would be charged for a passport. A $450 fee was bad enough. For many citizens, the new fee of $2350.00 has priced renunciation beyond their ability to pay. The $2350.00 fee effectively denies them their constitutional right to renounce.
“Renunciation of citizenship is a right guaranteed to all, not a privilege reserved for a few. As such, the US government *must* provide the necessary service at no or low cost. If a renunciation application actually costs the State Department $2350.00 then it is its responsibility to simplify its procedure thereby reducing those costs.
“Perhaps a lesson can be taken from the German government’s renunciation procedure. The application form is available online. The applicant fills out the form and mails it in with certified copies of a couple of documents. No fee. No in-person interviews. No fancy ceremonies. The renunciation is considered in effect when a certificate is received by the applicant. Simple. Efficient. Cost-effective. There is no need for the complexity with which the US State Department’s process is currently burdened.”
If anybody wants to submit that comment under their own moniker I’d be delighted!
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“ricard” notes:
At the site you mention one can submit a comment with complete anonymity. There is no requirement to give any name. I mention this in case anyone else has been put off from commenting by thinking it is necessary to give real identification. Take you chance.
I am inclined to feel trusting. I do not think they will be recording IP addresses and hunting down people whose comments they don’t like.
It surprises me that they are only showing 34 comments received.
Dash and EmBee:
In fact, the State Department itself claims, at the link in the post, that documenting a renunciation is extremely costly and time-consuming; i.e. “complex”. By this they claim to justify the $2,350.00 fee.
“The CoSM demonstrated that documenting a U.S. citizen’s renunciation of citizenship is extremely costly, requiring American consular officers overseas to spend substantial amounts of time to accept, process, and adjudicate cases. For example, consular officers must confirm that the potential renunciant fully understands the consequences of renunciation, including losing the right to reside in the United States without documentation as an alien. Other steps include verifying that the renunciant is a U.S. citizen, conducting a minimum of two intensive interviews with the potential renunciant, and reviewing at least three consular systems before administering the oath of renunciation. The final approval of the loss of nationality must be done by law within the Directorate of Overseas Citizens Services in Washington, DC, after which the case is returned to the consular officer overseas for final delivery of the Certificate of Loss of Nationality to the renunciant. These steps further add to the time and labor that must be involved in the process. Accordingly, the Department is increasing the fee for processing such requests from $450 to $2,350. As noted in the interim final rule dated June 28, 2010 (77 FR 36522), the fee of $450 was set substantially below the cost to the U.S. government of providing this service (less than one quarter of the cost). Since that time, demand for the service has increased dramatically, consuming far more consular officer time and resources, as reflected in the 2012 Overseas Time Survey and increased workload data. Because the Department believes there is no public benefit or other reason for setting this fee below cost, the Department is increasing this fee to reflect the full cost of providing the service. Therefore the increased fee reflects both the increased cost of the provision of service as well as the determination to now charge the full cost.”
Someone mentioned that they were told by some on the staff at the Vancouver consulate that consular staff pleaded with the State Department not to raise the renunciation fees. I don’t think they’d go to that effort (and actually tell a citizen that) if they felt it was justified. What complete BS!
@Mark Twain
There should be some cost analysis done between gaining and losing US citizenship and any justification for why the US government would put less effort into vetting potential citizens (if in fact they do).
The US government has a real problem with rejection.
would not be a scientific survey, how much face time did those
who reported their experience in our database
I will start. I spent less than 2 hours with consular officials over two visits in Montreal
I can’t see/open the comments on the Federal Register site for this rule.
http://www.regulations.gov/#!documentDetail;D=DOS_FRDOC_0001-2956
‘Fee Schedules: Consular Services; Visa and Citizenship Services Fee Changes’
Docket ID:DOS_FRDOC_0001
Topic(s):Consular Services, Fees, Passports and Visas
Document Type:Rule
Status:Posted
Received Date:Aug 28, 2014
Start-End Page:51247 – 51254
Comment Start Date:Aug 28, 2014
Comment Due Date:Oct 21, 2014
Page Count:8
The page says that some agencies may choose to redact the comments:
“Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.”
I have gotten a receipt for my query:
Perhaps I will get an answer.
@calgary411
Ah yes–the good old “comment on the process of making comments” 🙂 .
I see that the count is up to 55 comments. But of those, how many will be redacted?
We should be able to see the comments by clicking on “open docket folder” and if necessary, limiting to ‘public comments’ in the list of filters down the left side. But it doesn’t work for this rule though I tested it on other recent ones.
Imagine asking people “How do you like the new fee”. Now who in their right might would answer yes to that. It’s like a survey at the gas pumps asking if you like paying 10.00 a liter for gasoline. I guess the brilliant person that published that thinks we’re less than stupid. Geeze!
Answer to my query:
Current Assignees: Danielle F
Request Information:
Question or Comment: Comment
Thank you for following up on that @calgary411. I trust nothing that comes from the US government is what it purports to be.
Ex.
“……….however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. ….”
They can just supress commentary and criticism while pretending to democratically solicit it.
Or to supress dissent and voices of opposition on sensitive issues that involve the US violation of its own laws about the right to renounce, as well as international human rights to choose one’s citizenship?
As Bubblebustin said in September:
“There should be some cost analysis done between gaining and losing US citizenship and any justification for why the US government would put less effort into vetting potential citizens (if in fact they do).
The US government has a real problem with rejection.”
I would add this If U.S. citizenship really is as valuable as people in the U.S. claim it is — supposedly more valuable than citizenship in other countries — why should it cost more get rid of it than to acquire it??
That’s very strange economics as well as strange marketing. People may be lining up to join the club, but once they’ve joined, the club damned well doesn’t want them to leave and stop paying dues, and it charges a lot to let them go. It sounds like a scam to me.
@AnonAnon
It’s a revolving door going in, and a spanking machine going out, lol!
#potus banks the midterms on #EconomicPatriotism & tries to coverup his own #refugee statistics
http://bit.ly/1sLV5mJ
Everyone:
If you have NOT voiced your concern on the website below does that mean that you are quite OK with the Department of State (DOS) massive increase in renunciation fee?
Or are you just afraid to send an email to the site? If you are afraid use an alias or get someone else (a pure Canadian perhaps — I actually find such people more afraid of DOS and IRS than angry “US persons”) to send the email.
The DOS will reasonably assume that if there are few responses, no one cares.
Our ACDS-ADSC Washington D.C. attorney, Mr. Jim Butera of Jones Walker, just spoke to DOS — and informed me that the deadline for responses has been extended to October 26 (a Sunday).
Don’t be afraid. Remember the words of @Wondering. You have a right to complain. Send in your comments today.
If you comment, could you also provide your comment on this thread?
http://www.regulations.gov/#!documentDetail;D=DOS_FRDOC_0001-2956
Only 63 comments received so far.
63
Thanks for the update, Stephen, on the extended opportunity for our voices to be heard.
We must take every opportunity to help our cause in every way that presents itself. No, we are not OK with that obscene increase and we need to say that in as many ways as possible.
Thanks for the kick in the butt to get going on this. I just submitted my comment:
Dear U.S. Department of State:
The USA has no moral authority to equate citizenship – where the definition of citizenship has nothing do with economic, emotional, or residential ties to the US – with taxpayer status. No other country does this (except Eritrea). But even Eritrea’s definition of citizen/taxpayer is not nearly as broad as USA’s, nor is that dictatorship’s taxation and reporting burdens on its citizens nearly as burdensome and life restricting as is the USA’s.
It is no secret, that since the USA has made recent attempts through FATCA at enforcing ‘US person’ taxation on people who live and earn, solely and permanently outside USA, that relinquishment and renunciation numbers have dramatically increased. Who can blame these people for wanting to live a normal life in the countries they call home? US citizenship-based taxation (more accurately termed ‘US person’ taxation) creates many serious restrictions on how they arrange their finances in the countries they call home.
Even before USA raised its renunciation fee from $450 to $2,350, it was a huge burden to renounce because a ‘US person’ in most cases would have to figure out, at great expense, and risk, how to come into US tax compliance – most ‘US persons’ living outside USA were not aware of the non-intuitive, unique to the world, American law that confers taxpayer status on them.
What a kick in the teeth it is, to not only have to pay legal and accounting fees, and risk penalties to resolve this mess (most, although not all US persons living their lives outside USA would actually owe no taxes), but to now also have to cough up a $2,350 renunciation fee. This is the highest renunciation fee of any country in the world, yet people are still lining up at US consulates(waiting months for an appointment), to get rid of the noose around their necks.
The average ‘US person’ is just that – average, and most will take a huge hit financially dealing with the whole messy business of trying to free themselves from what has become a ridiculous, unnecessary, immoral, attempt to drastically eliminate the freedom of law-abiding, decent people who do not live in the ‘land of the free’.
I have a suggestion. Instead of making this renunciation process a living nightmare for people whose only ‘crime’ was birth on US soil (or holding an expired green-card, or having an American parent), why not have a simple form with a one liner such as: Do you want to be a US citizen? Charge a couple hundred bucks for it if you need to, to cover expenses, drop all the ridiculous past-compliance requirements, and amnesty programs. Keep FATCA and citizenship-based taxation if you must; we won’t care because we won’t be US citizens, and let us get on with the business of living our lives.
You do realize that hundreds of thousands of ‘US persons’ throughout the world have become anti-ambassadors for the USA. Your prompt attention to this problem might make us change our minds and encourage us to speak positively of our birth country once again. Your call.
ONLY FIVE more days left (until October 26) to complain to the Department of State about the massive increase in renunciation fee.
We can complain to each other but why don’t you also tell the United States Department of State your thoughts on the subject?
If WhiteKat (see her post above), who I know to be one of the more shy soft-spoken Brockers, is brave enough to post a comment to the DOS, you can too.
Don’t be afraid. Post it today at:
http://www.regulations.gov/#!documentDetail;D=DOS_FRDOC_0001-2956
@Stephen,
I wonder if the comment counter is working properly. There should be at least 64 now, since I submitted my comment, but the counter still shows 63. I know my comment got through because I got a reference number afterwards.
Would anyone else who has not yet submitted a comment like to try, and see if the total comments number changes?
@WhiteKat, like you I have submitted a comment several days ago, and received a tracking number, but the counter hasn’t changed.
I put in a comment back on Sept 25 and when I search on the tracking number, here’s what I get:
“Comment Tracking Number Match
This comment was received in Regulations.gov but is not yet posted. Please contact the agency directly for more information.”
It’s not posted yet, so I’m assuming it’s not part of the number being displayed.
Sunday (tomorrow) is the last chance to post your thoughts on the renunciation fee increase to the U.S. Department of State.
Those who are afraid can use a alias name and alias email account.
In your email of complaint, maybe you will express the opinion, as suggested by @MuzzledNoMore, that there should be NO fee whatsoever required for expatriation since it is a fundamental human right..
Stephen, if I am looking in the right place, it says that the Status is Closed for
‘Fee Schedules: Consular Services; Visa and Citizenship Services Fee Changes’
Rule
Posted:
08/28/2014
ID:b DOS_FRDOC_0001-2956
“More Document Details
Docket ID:DOS_FRDOC_0001
Topic(s):Consular Services, Fees, Passports and Visas
Document Type:Rule
Status:Posted
Received Date:Aug 28, 2014
Start-End Page:51247 – 51254
Comment Start Date:Aug 28, 2014
Comment Due Date:Oct 21, 2014
Page Count:8”
And I can’t see any of the >60 comments anywhere. A notice on the side states that they can redact and withhold any comments if they so choose:
““Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.”