The Quarterly Publication of Individuals Who Have Chosen to Expatriate for Q1 2017 has just been placed on public inspection for printing in Wednesday’s Federal Register, ten days later than required by law. This quarter’s list contains 1,313 “published expatriates”, in contrast to the FBI’s NICS gun control database which counted 1,484 renunciants for the first three months of the year (and another 460 in April).
NICS only includes people who renounce citizenship under 8 USC § 1481(a)(5). In other words, it is supposed to cover a smaller population than the Federal Register list, which includes § 1481(a)(1) – (4) relinquishers as well. So it’s clear that not all ex-citizens get their names published in the Federal Register, though there seems to be neither rhyme nor reason behind that long-standing phenomenon — (a)(5) renunciants & (a)(1) relinquishers, rich & poor, covered & uncovered expatriates, and filers & non-filers of 8854 alike are among both the published and the unpublished.
All we can say for sure is that either the State Department is not forwarding some CLNs to the IRS, or the IRS is not publishing the names from all the CLNs they receive. (Given that State should be forwarding CLNs to both the FBI and the IRS, and the FBI clearly have been receiving CLNs, I’d guess that the problems are the IRS’ fault.) It’s clearer why tens of thousands of people who abandon their green cards each year don’t show up in the list either: USCIS isn’t providing the IRS with the information they need about those folks, as we’ve discussed in more detail previously.
We still can’t tell whether the U.S. election results are having any effect on the numbers, because it’s not clear when the people named in this quarter’s list actually went and paid that $2,350 to the U.S. government — I’m not having much luck matching the names in this quarter’s list to media reports. One person in this quarter’s list is known to have relinquished in June 2016, but I can’t find any others who have previously spoken with the media about giving up U.S. citizenship. If you know the date anyone in this quarter’s list (whether yourself or a public figure) had their final appointment at the consulate, please leave a comment.
Table of contents
Table of recent relinquishments by public figures
A few more additions to the table this month. Ghanaian Deputy Finance Minister Charles Adu Boahen started the procedure to renounce his U.S. citizenship in December 2016, and said the U.S. Embassy in Accra made him attend three interviews for some reason. Chris Hart, a musician in Japan, acquired Japanese nationality and so will have to provide the Japanese government with his CLN with two years, but it’s not clear whether he’s started the process of obtaining one yet. I have not yet included Randall Dietz of Australia in the table — the Sunshine Coast Daily reported that he is trying to raise funds to pay for the State Department’s absurd CLN fee, but he does not seem to have actually renounced nor performed any other relinquishing act yet.
Unfortunately, only one person from the table showed up in this quarter’s list — Frank Alpert, who renounced nearly a year ago. It’s likely that some people in the list renounced later than he did, though it’s not clear whether we’re starting to see November & later renunciations yet. Update, 10 May: In a comment, Shadow Raider points out one famous name I missed: the president of Peru, who renounced way back during campaign season in November 2015. Also, three other Brockers in the list mention that they had their final consular appointments in January, August, and the last quarter of 2016. So State and the IRS are still clearing up a backlog from as long as eighteen months ago, though it looks like post-election renunciations are finally starting to come in — with no evidence of any sudden slowdown or speed-up, contrary to all the media hype.
In the early years of the list, some people took nearly six years to show up — like author Shere Hite, who renounced in 1995 but didn’t get her name published until the much-delayed Q2 2001 list. However, in more recent years, if your name hasn’t shown up within about 18 months, it’s likely that State & the IRS just forgot about you entirely. You can always call up the Philadelphia IRS office and remind them to print your name, the way Mike Gogulski did.
Name | Occupation | Other citizenship |
Giving up US citizenship | Appeared in Federal Register? |
Source | |
---|---|---|---|---|---|---|
Reason | Date | |||||
Rachel AZARIA | Politician | Israel | Take office as Member of Knesset | January 2015 | Q2 2016 | Times of Israel |
Jonathan TEPPER | Macroeconomic analyst | United Kingdom | FATCA & other U.S. tax reporting requirements | January 2015 | Q1 2016 | The New York Times |
David ALWARD | Politician | Canada | Become Canadian consul-general in Boston | April 2015 or earlier | Q3 2015 | Canadian Broadcasting Corporation |
YANG Chen-ning | Physicist | China | Restore Chinese citizenship | April 2015 | Q3 2015 | Xinhua (China) |
Andrew YAO Chi-chih | Computer scientist | China | Restore Chinese citizenship | Unclear | Q3 2015 | Xinhua (China) |
Alfred Oko VANDERPUIJE | Politician | Ghana | Stand for election to Parliament | August 2015 | No | Starr FM (Ghana) |
Philip RYU | Singer | South Korea | Serve in South Korean army | September 2015 or earlier | No | Money Today (South Korea) |
Pedro Pablo KUCZYNSKI | Politician | Peru | Run for president | November 2015 | Q1 2017 | El Comercio (Peru) |
Rachel HELLER | Writer | Netherlands | FATCA & other U.S. tax reporting requirements even when no U.S. tax is owed | November 2015 | Q4 2016 | Blog (will be in TV news programme at a later date) |
Susan WOOD | Unknown | Canada | FATCA & other compliance issues | November 2015 | Q3 2016 | Vancouver Sun |
KANG Dong-suk | Violinist | South Korea | Restore South Korean citizenship | 2015 (month not specified) | No | News1 (South Korea) |
Pavel BURE | Ice hockey player | Russia | “US passport was no longer needed” | Early 2016 (month not specified) | Q4 2016 | Sputnik News; Pravda Report |
Neil (Teodoro) LLAMANZARES | Businessman | Philippines | Public opinion (his wife ran for President, but lost after he renounced) | April 2016 | Q3 2016 | Rappler (Philippines) |
TAO Yuequn | Businessman | China | Unknown | April 2016 or earlier | No | Sina Finance |
LEE Chih-kung | Physicist | Taiwan | Appointed Minister of Economic Affairs by President-elect Tsai Ing-wen | May 2016 | Q3 2016 | Apple Daily (Taiwan) |
Ned (Nader) MANNOUN | Politician | Australia | Run for Australian parliament | May 2016 or earlier | Q4 2016 | Liverpool Champion (Australia) |
Yehuda GLICK | Politician | Israel | Take office as Member of Knesset | May 2016 | No | Arutz Sheva (Israel) |
Karen ALPERT | Academic | Australia | FATCA & other compliance issues | June 2016 | Q4 2016 | Sydney Morning Herald |
Frank ALPERT | Academic | Australia | FATCA & other compliance issues | June 2016 | Q1 2017 | Sydney Morning Herald |
Judy CHAN Ka-pui | Politician | Hong Kong | Run for Hong Kong Legislative Council | July 2016 | Q3 2016 | Apple Daily (Hong Kong) |
Boris JOHNSON | Politician | United Kingdom | Taxes or politics or whatever | July 2016 or earlier | Q4 2016 | Daily Mail |
Kimi ONODA | Politician | Japan | Dual-at-birth, did Japanese-law “choice of nationality”, didn’t know U.S. still considered her a citizen | October 2016? | No | Viewpoint (Japan) |
Charles Adu BOAHEN | Politician | Ghana | Become Deputy Minister of Finance | Early 2017 | No | Ghana Guardian |
Chris HART | Musician | Japan | Naturalise in Japan | March 2017 or later | No | Sports Hochi (Japan) |
Comparison with NICS
The below table lists the yearly additions to NICS from 2006 to 2010, and monthly additions for 2011 up through the present, compared with the quarterly lists in the Federal Register.
The FBI has the bad habit of uploading the new NICS report each month at the same URL as the old one; the only way to keep a verifiable collection of old reports is to save old ones in some archiving service each month, and unfortunately we didn’t remember to do this for all months, though we’ve had a good track record over the past year. If the month is set in upright type, the link goes to an actual Internet Archive copy of the FBI NICS report for that month. If the month is in bold type (for December), the link goes to the NICS annual operations report for the appropriate year. Finally, for months in italics, the link goes to a Brock post or comment.
Unfortunately, some previously-saved reports (e.g. the February 2017 report) seem to have disappeared from the Internet Archive. I’m not sure whether this is a temporary issue or what.
First quarter | Second quarter | Third quarter | Fourth quarter | ||||||||
---|---|---|---|---|---|---|---|---|---|---|---|
FR citation |
Addi- tions |
FR citation |
Addi- tions |
FR citation |
Addi- tions |
FR citation |
Addi- tions |
Year-end total |
|||
71 FR 25648 | 100 | 71 FR 50993 | 31 | 71 FR 63857 | 41 | 72 FR 5103 | 106 | ||||
Annual totals for 2006 | Fed. Reg. | 278 | NICS | 48 | 12,651 | ||||||
72 FR 26687 | 107 | 72 FR 44228 | 114 | 72 FR 63237 | 105 | 73 FR 7631 | 144 | ||||
Annual totals for 2007 | Fed. Reg. | 470 | NICS | 317 | 12,968 | ||||||
73 FR 26190 | 123 | 73 FR 43285 | 23 | 73 FR 65036 | 22 | 74 FR 6219 | 63 | ||||
Annual totals for 2008 | Fed. Reg. | 231 | NICS | 655 | 13,623 | ||||||
74 FR 20105 | 67 | 74 FR 35199 | 15 | 74 FR 60039 | 158 | 75 FR 9028 | 503 | ||||
Annual totals for 2009 | Fed. Reg. | 743 | NICS | 714 | 14,337 | ||||||
75 FR 28853 | 179 | 75 FR 69160 | 560 | 75 FR 69158 | 397 | 76 FR 7907 | 398 | ||||
Annual totals for 2010 | Fed. Reg. | 1,534 | NICS | 1,009 | 15,346 | ||||||
First quarter | Second quarter | Third quarter | Fourth quarter | ||||||||
Month, year |
Addi- tions |
Month-end total |
Month, year |
Addi- tions |
Month-end total |
Month, year |
Addi- tions |
Month-end total |
Month, year |
Addi- tions |
Month-end total |
Apr 2011 | 41 | 15,387 | Jul 2011 | 89 | 15,705 | Oct 2011 | 118 | 15,930 | |||
May 2011 | 98 | 15,445 | Aug 2011 | 54 | 15,759 | Nov 2011 | 40 | 15,970 | |||
Jun 2011 | 131 | 15,616 | Sep 2011 | 53 | 15,812 | Dec 2011 | 34 | 16,004 | |||
Q2 total | 270 | Q3 total | 196 | Q4 total | 192 | ||||||
76 FR 27175 | 499 | 76 FR 46898 | 519 | 76 FR 66361 | 403 | 77 FR 5308 | 360 | ||||
Annual totals for 2011 | Fed. Reg. | 1,781 | NICS | 656 | 16,004 | ||||||
Jan 2012 | 265 | 16,269 | Apr 2012 | 204 | 16,662 | Jul 2012 | 22 | 17,188 | Oct 2012 | 3,106 | 20,577 |
Feb 2012 | 98 | 16,367 | May 2012 | Missing | Aug 2012 | 149 | 17,337 | Nov 2012 | 97 | 20,654 | |
Mar 2012 | 89 | 16,458 | Jun 2012 | 504 | 17,166 | Sep 2012 | 114 | 17,451 | Dec 2012 | 0 | 20,654 |
Q1 total | 452 | Q2 total | 708 | Q3 total | 285 | Q4 total | 3,203 | ||||
77 FR 25538 | 460 | 77 FR 44310 | 189 | 77 FR 66084 | 238 | 78 FR 10692 | 45 | ||||
Annual totals for 2012 | Fed. Reg. | 932 | NICS | *4,648 | W/o backlog: ~1,700 |
||||||
Jan 2013 | 176 | 20,830 | Apr 2013 | 319 | 21,823 | Jul 2013 | 298 | 22,908 | Oct 2013 | 302 | 23,557 |
Feb 2013 | 478 | 21,308 | May 2013 | 374 | 22,197 | Aug 2013 | 278 | 23,186 | Nov 2013 | 118 | 23,675 |
Mar 2013 | 196 | 21,504 | Jun 2013 | 413 | 22,610 | Sep 2013 | 69 | 23,255 | Dec 2013 | 132 | 23,807 |
Q1 total | 850 | Q2 total | 1,106 | Q3 total | 645 | Q4 total | 552 | ||||
78 FR 26867 | 679 | 78 FR 48773 | 1,130 | 78 FR 68151 | 560 | 79 FR 7504 | 631 | ||||
Annual totals for 2013 | Fed. Reg. | 3,000 | NICS | 3,153 | 23,807 | ||||||
Jan 2014 | 320 | 24,127 | Apr 2014 | 382 | 24,602 | Jul 2014 | 577 | 26,000 | Oct 2014 | 426 | 26,916 |
Feb 2014 | 95 | 24,222 | May 2014 | 205 | 24,807 | Aug 2014 | 180 | 26,180 | Nov 2014 | 187 | 27,103 |
Mar 2014 | -2 | 24,220 | Jun 2014 | 616 | 25,423 | Sep 2014 | 300 | 26,480 | Dec 2014 | 137 | 27,240 |
Q1 total | 413 | Q2 total | 1,203 | Q3 total | 1,057 | Q4 total | 750 | ||||
79 FR 25176 | 1,001 | 79 FR 46306 | 576 | 79 FR 64031 | 776 | 80 FR 7685 | 1,062 | ||||
Annual totals for 2014 | Fed. Reg. | 3,415 | NICS | 3,423 | 27,240 | ||||||
Jan 2015 | 271 | 27,511 | Apr 2015 | 767 | 29,413 | Jul 2015 | 856 | 30,973 | Oct 2015 | 194 | 31,869 |
Feb 2015 | 105 | 27,616 | May 2015 | 543 | 29,956 | Aug 2015 | 552 | 31,525 | Nov 2015 | 318 | 32,187 |
Mar 2015 | 1,030 | 28,646 | Jun 2015 | 161 | 30,117 | Sep 2015 | 150 | 31,675 | Dec 2015 | 479 | 32,666 |
Q1 total | 1,406 | Q2 total | 1,471 | Q3 total | 1,568 | Q4 total | 989 | ||||
80 FR 26618 | 1,335 | 80 FR 45709 | 460 | 80 FR 65851 | 1,426 | 81 FR 6598 | 1,058 | ||||
Annual totals for 2015 | Fed. Reg. | 4,279 | NICS (-10) | 5,416 | 32,666 | ||||||
Jan 2016 | 253 | 32,919 | Apr 2016 | 860 | 34,807 | Jul 2016 | 350 | 36,378 | Oct 2016 | 440 | 37,346 |
Feb 2016 | 539 | 33,458 | May 2016 | 765 | 35,572 | Aug 2016 | 252 | 36,630 | Nov 2016 | 227 | 37,573 |
Mar 2016 | 489 | 33,947 | Jun 2016 | 456 | 36,028 | Sep 2016 | 276 | 36,906 | Dec 2016 | 430 | 38,003 |
Q1 total | 1,281 | Q2 total | 2,081 | Q3 total | 878 | Q4 total | 1,097 | ||||
81 FR 27198 | 1,158 | 81 FR 50058 | 509 | 81 FR 79098 | 1,379 | 82 FR 10185 | 2,365 | ||||
Annual totals for 2016 | Fed. Reg. | 5,411 | NICS (-16) | 5,321 | 38,003 | ||||||
Jan 2017 | 377 | 38,380 | Apr 2017 | 460 | 39,947 | Jul 2017 | Oct 2017 | ||||
Feb 2017 | 344 | 38,724 | May 2017 | Aug 2017 | Nov 2017 | ||||||
Mar 2017 | 763 | 39,487 | Jun 2017 | Sep 2017 | Dec 2017 | ||||||
Q1 total | 1,484 | Q2 total | 460 | Q3 total | Q4 total | ||||||
82 FR 21xxx | 1,313 | ||||||||||
Totals so far for 2017 | Fed. Reg. | 1,313 | NICS | 1,944 | 39,947 |
Same caveats as previous editions of the table. The “addition” figure for April 2011 refers to all additions since December 2010. The “addition” figure for October 2012 includes what the FBI described as a “backlog” of 2,900 renunciant records, also included in the annual total for that year. I also gave an estimate of what the annual total would be without the backlog, even though some of the backlog may relate to other periods covered by the chart. Finally, the annual figures for 2015 and 2016 are smaller than the sum of the monthly additions because I subtracted out erroneous renunciant records submitted by U.S. state governments; see the Active Records in the NICS Index by State reports for 2015 and 2016.
Conclusion
With last month’s hearing on FATCA, Congress finally took the first steps towards formally acknowledging our issues — over the vociferous objections of the Democratic witness who claimed that emigrants giving up citizenship because of bad laws don’t matter because immigrants who aren’t affected by those laws continue to naturalise. However, a first step is not a solution. Neither Congress nor the president have yet released a concrete tax reform plan which addresses our issues, and even if they do there’s no guarantee they can pass it — particularly if Democrats oppose the whole thing and certain Republican senators want to tweak it to ensure the diaspora keeps getting screwed.
Until there’s a solution in sight, people will simply keep on snapping up all available renunciation appointment slots.
You cannot trust the political pukes in D.C. to tell the real truth about anything. They are so used to spinning (lying) that they do it habitually. If they say they are trying to fix something it means they are tearing it down or worse yet doing nothing. All reports are subject to editing by officials so it fits his narrative.
Pray for a miracle/The miracle you want is the FairTax. It is the only taxing system that does what a tax should do…Saves the nation from playing out the Saul Alinsky’s Rules for Radials.
Congress and Senators alike know that the FairTax is the only taxing system that can be sustained.
Promote The FairTax as the only system that will stop the nonsense and the expats from giving up their citizenship.
See here I made the list:
Brumfield, Daniel Raymond.
Relinquished: 5 Oct 2015
Applied for appointment: 5 Oct 2015
Received appointment: Nov 2015
Appointment: 19 Jan 2016
CLN approved: Sep 2016
Freedom list: May 2017
Pedro Pablo Kuczynski, the current president of Peru, is on the list this time. He renounced in November 2015.
Now you all know what a racquet this is,…. accountants, lawyers, officials with badges and lot’s of forms! ARGHHH
This is not a myth:
– I’m on the list.
– Renounced in Q4 2016.
– My decision had nothing to do with election outcome.
Thank you for the list news.
My name is also on this list.
I renounced in London (August, 2016). My name is appearing in the Federal Registry now 8.5 months after I renounced.
SCOTUS reacting to a current citizenship case:
https://www.youtube.com/watch?v=hwEwDVy6gw4
Starting at 4:35, note how the talking head gets it wrong. He says Justice Kennedy won’t tolerate a Government position that demeans THE INDIVIDUAL.
That’s not Justice Kennedy’s position. To hell with the law, what Kennedy won’t tolerate is anybody coming before the SCOTUS saying that U.S. citizenship isn’t utterly priceless.
30 Year IRS Vet says:
Great post. Whether you are on the list or off the list it is usually a pretty good idea to make sure the IRS
Renounced 17 August 2016, and on this list. Karen Tilley
30 Year IRS VET says,
Great Post. Whether you are “on the list or off the list,” it is usually a good idea to make sure the IRS has your “last known address,” a legal term which means the IRS has no duty under long standing case law to hunt down an American abroad with whom Uncle Sam believes there is still unfinished business. An American abroad can put his head in the sand once he exits the country but experience teaches that very often, especially when the IRS makes a mistake or has incomplete information to make a determination, a simple timely response may be all that is needed to make the IRS go away. Otherwise, the situation can become a Hotel California-“you can check out anytime you like but you can never leave.”
See http://mopsicktaxlaw.blogspot.com/2017/04/americans-abroad-welcome-to-hotel.html
@30 Year vet
Perhaps good advice for some select people. But terrible advice for many, many others.
“…it is usually a good idea to make sure the IRS has your “last known address,” ”
Nope. That’s the opposite of a good idea.
No communication at all is my idea of a good idea.
They had my “last known address” from my “last known return”, but did it do me any good? Did they send just one piece of information about how they moved the goal posts after lying twice on the phone about where they stood in the first place? They can crawl down in the cellar and search though all those stacks of old paper collecting mold when they need it.
@Wilton Jere Tidwell
“Promote The FairTax as the only system that will stop the nonsense and the expats from giving up their citizenship.”
Youre heading almost in the right direction.Firstly, I don’t want your citzenship. Secondly, the americans abroad and at home can kiss their SS pensions goodbye.Homelander can forget their medicare and any other programs and the poor can all go to hell. LOTSA LUCK.
FairTax is like going back in time.
“All we can say for sure is that either the State Department is not forwarding some CLNs to the IRS, or the IRS is not publishing the names from all the CLNs they receive.”
The IRS isn’t publishing the names of all the 8854s they receive. We don’t even need to look for CLNs.
‘it is usually a good idea to make sure the IRS has your “last known address,”’
You mean like sending Form 8821 to the IRS office where we filed our last returns and is still supposed to cover the state where we still live?
You mean like reminding the IRS over and over again, in response to letters that they persisted in sending to our old address?
I even had to argue over the phone. One IRS agent actually understood that we had moved, but it took a long time to convince her that the IRS should act on the information that we provided on Form 8821 and letters and phone calls. I told her that the date was approaching when Japan Post would stop forwarding, and when Japan Post looks at the return address on an undeliverable letter and sees “PA” at the end they will understand that the country to return it to is Panama. She finally partially updated IRS records of our address so now the IRS leaves out the state but provides enough correct information to make their letters deliverable, but return addresses still end with abbreviations of other countries instead of “US”.
Of course I’m far angrier about embezzlement and ongoing malfeasance trying to cover up the embezzlement, but I still tried really really hard to let them know where to find me.
Do you know any way to make sure they have our “last known address”? Idiots.
@Eric
Very nice effort even though the Shame list seems incomplete ,if not misleading , and focuses mostly on noteworthy people.Does the National Registry go back to the 60’s ? Can one find out in some way whether they still are listed as US citzens . It is a known fact that the Canadian government informed the US government when americans acquired canadian citzenship back in the day and the DOS might have tinkered without issueing a LCN.
Oh, Mr. Mopsick. I thought people were wrong about you, I thought you were just reporting the way things are and not saying they were right, but now you’re every bit as misleading as your cohorts.
“The IRS will customarily issue several notices asking the targeted taxpayer to respond to provide an opportunity to resolve the tax matter.”
IRS notices tell us to make toll free calls to US phone numbers but ATT refuses to connect. From Japan I dialled 00539-111 and told ATT operators that I was trying to obey instructions from the US government but they refused to connect toll free calls.
IRS notices say we can write to addresses on IRS notices. Sure we can write. Is there any way to get replies? The IRS ignored more than 50 letters from me before they filed a lien. They’ve ignored around 50 more after that too, though they replied to a few after that.
Among the few cases where the IRS replied, even fewer had sufficient postage. Have you seen the IRS’s published position that the post office will not deliver mail without proper postage? Their published position is wrong sometimes but not always, but even when their position is wrong because their notices accidentally get delivered, their notices are still reasonably calculated to be not legally notices.
Many of the IRS’s notices don’t show how much postage thay paid, nor mailing dates. Those sent by International Surface Air Lift from the US usually arrive in a few weeks, later than the 10 day deadline stated in the notices for us to reply, but it doesn’t matter because the IRS ignores our replies anyway. Those sent by sea mail from Germany or the UK, and even those sent by air mail from the UK, usually arrive after more than a month, but who knows when they were actually mailed.
“All they have to do is copy the address they have from the most recent tax return you filed.”
Huh. So is that why they ignore Form 8821 change-of-address form? Why do they even publish the form?
“IRS notices start out looking like junk mail and then work their way up to certified letters.”
International mail can’t be certified. It can be registered but USPS loses a lot of registered mail that’s addressed to the IRS. Registered letters can be tracked on web sites of both Japan Post and USPS. USPS shows letters traversing US post offices and then disappearing into black holes.
“Using a very simple “what if” scenario, assume the IRS commences a correspondence audit with a taxpayer who simply blows off all his IRS mail and moves overseas to take a job.”
Or what if the taxpayer has already lived in the rest of the world for decades and the IRS REFUSES to audit and courts even deny motions trying to compel the IRS to audit?
“Assume also that the correspondence audit ends up with the issuance of a Statutory Notice of Deficiency.”
Or what if the IRS REFUSES to issue a Statutory Notice of Deficiency? The Internal Revenue Manual, regulations authorized by statute, compel the IRS to issue a Notice of Deficiency when the taxpayer requests, but the IRS doesn’t have to obey the law.
You forgot a step too. The law requires the IRS to issue a Notice CP2000, and depending on how the IRS’s records have been corrupted the IRS doesn’t even legally have a choice to skip issuing a CP2000 … but the IRS doesn’t have to obey the law.
When the IRS rejects a claim on a return, the law requires the IRS to issue a notice by certified or registered mail (among which only registered works) and state what part of the claim it’s rejecting … but the IRS doesn’t have to obey the law.
“A timely response to a Statutory Notice of Deficiency gives the taxpayer a chance to tell his story to a relatively higher level IRS employee who has the actual authority to make a decision for the government, and, if necessary, to a U.S. Tax Court judge.”
That only happens in lucky cases where the IRS obeys a law.
“Once the taxpayer defaults because of a failure to file a petition within the allotted time, it becomes legal for the IRS to start issuing actual invoices requesting payment.”
Huh? As far as I can tell, it was already legal for the IRS to issue that kind of notice without even issuing a Notice of Deficiency. This seems to be a rare case where an IRS action actually didn’t violate a law.
“A defaulted Statutory Notice of Deficiency allows the IRS to enter the liability on its books. This is called an “assessment.””
Sort of. Somehow the IRS is allowed to assess even without a Notice of Deficiency.
By the way, this kind of “assessment” is nothing like a Canadian assessment. The CRA sends assessments automatically, but to get the same kind of information from the IRS you have to send Form 4506-T to request a “transcript”. You’d better send two 4506-T’s every year, one for transcript of return and one for transcript of payments such as withholding. If you wait for an IRS lien to reveal that the IRS didn’t credit your payments, it will be too late because of a three year time limit. You’d better send two 4506-T’s every year whether or not you know of any reason why you need them.
“Welcome now to the world of IRS Collections.”
Oh yeah? The law says the IRS can’t collect until they’ve assessed, but so what? The IRS doesn’t have to obey the law, and courts don’t make them. The IRS can collect an unassessed penalty because the law isn’t worth the paper it’s printed on.
“It doesn’t take long for the IRS to lose all patience with an unresponsive taxpayer and start the levy process, usually to administratively seize income and money in bank accounts. Let’s assume the IRS computer cannot find anything to seize in the taxpayer’s name in the United States.”
Yeah, then they file the lien in the District of Columbia, even when the lien is completely fraudulent in the first place. And even when they DO know how to find assets in the US, and even when they’ve received payments that financial institutions withheld from accounts, the IRS STILL doesn’t have to obey the law.
Enough with your theories about how the IRS is supposed to work, as if laws counted for anything. Mr. Mopsick, you spent 30 years there, you ought to know how the IRS ACTUALLY works.
Hi, this is Frank Alpert (spouse of Karen Alpert). My occupation on your list can be stated as Academic (instead of ?). Free at last.
The 2016 number was said to be 5411, over 4279 from 2015. If we take the lower Q1 figure of 1313, this suggests a 2017 total of around 5200, which would be a slight decline. The higher figure of 1484 would give us over 5900, for another record year. (I am assuming–probably incorrectly–that renunciations are not seasonal.)
It is often supposed that the Federal Register delays or avoids reporting the names of many renunciates, in order to bring the total down and make the USA look better. On the other hand, an anti-Trump bureaucrat might conceivably want a higher number for 2017, in line with the narrative of a spike in Trump-motivated renunciations. Or it could all just be a result of randomness and disorganization. What pareidolic patterns are you seeing in these particular ceiling dots?
@30 Year IRS Vet,
I agree with @shovel and @iota.
And I’m surprised to see you posting here again – particularly after you decided to censor comments on your own commercial compliancer site.
One thing is for sure… none of the names on the 2017 Q1 renunciation list has anything to do with the ascension of Donald Trump to the presidency. If anyone *is* actually leaving the U.S. because of Trump they will need to be resident abroad for a number of years before they are eligible for citizenship in another country. Unless all anti-Trump migrants are willing to be stateless for the foreseeable future, the anti-Trump factor won’t be apparent on this list for several more years, if ever. (I doubt he’ll be elected for a second term.) Of course, there could be some Americans already abroad who were willing to put up with CBT and FATCA but aren’t willing to be a citizen of a country that has Donald Trump at the helm.
Thanks for keeping us informed of these important stats, Eric!
Re: Communicating with the IRS.
If I really wanted a penpal I think I’d prefer an ax murderer doing life in a Federal penitentiary over the IRS. At least the killer would be likely to respond promptly and intelligently, which is more than you can say about so-called “communications” from the IRS. I fully expect to never hear from the IRS again and I’m good with that.
@Frank: thanks & congratulations.
@Shadow Raider: d’oh, missed that one. Updated the list.
@MuzzledNoMore & Zla’od: Of course no one who “fled the Trump regime” is in this list. But my theory was that the election would have a few competing effects on different groups of people already abroad:
1. Some Republicans would cancel their previously-scheduled renunciation appointments in hopes of seeing tax reform soon
2. Some Democrats abroad who were afraid what their friends & family would say if they renounced now have a convenient excuse to go ahead with it
3. People who don’t really follow Homeland politics and were already on the fence about renouncing would be pushed over the edge by the general impression (e.g. what they read in their local papers) that the U.S. has gone nuts
Anyway, with not much change in the numbers, it looks like either I was wrong about some or all of those, or the latter two effects cancel out the former one.