158 thoughts on “1,313 published expatriates in Q1 Federal Register honour roll; 1,484 renunciants added to NICS for same period”

1. Good work again, Eric. I see that this quarter’s list contains “Ballmer Steven”, the name of a former CEO of Microsoft. That reinforces a point I have made before — that this is just a mysterious list of names, which may or may not correspond to specific actual people. Although I relinquished years ago, a name identical to my own has never appeared on a quarterly Federal Register list. If it does finally appear, I will have no way to know whether it corresponds to me or to someone else with the same name.

2. Andrew Mitchel’s post: http://intltax.typepad.com/intltax_blog/2017/05/2017-first-quarter-published-expatriates-a-total-of-1313.html

   Haven’t seen other blog or media coverage yet.

   @AnonAnon: That reinforces a point I have made before — that this is just a mysterious list of names, which may or may not correspond to specific actual people.

   Yes, that’s a good point. The US is only publishing this list for naming & shaming, so they give out enough information to titillate, but not enough to inform. Whereas other countries either don’t make renunciants’ information public at all, or they publish a lot more details about renunciants — birthdate, birthplace, other citizenship, even current address. But in those cases they’re doing it for transparency reasons, e.g. to make sure the government isn’t stripping people of citizenship illegally.

3. “(I doubt he’ll be elected for a second term.)”

   We were supposed to doubt he’d even be elected for a first term, but that doesn’t matter. Besides which, I didn’t doubt, but that doesn’t matter either. Regardless of whether two candidates deserved to lose on the merits, merits are just as meaningless in elections as they are in lawsuits.

   Second term? Nixon. Bush Jr (in fact, though the first time he was the people’s second-choice just like Trump, the second time he got a majority.) Obama. Clinton’s husband (the guy who got impeached). Don’t hold your breath.

   Even a friend who told me he would leave the US if Trump got elected didn’t leave. I suggested he could try to find out if he can claim Canadian citizenship by inheritance but he didn’t. I also told him my prediction that Trump was going to win.

4. ‘I see that this quarter’s list contains “Ballmer Steven”, the name of a former CEO of Microsoft.’

   Same name but it’s really hard to imagine him being the same person.

   Another Norman Diamond and I moved to Toronto at the same time. I never met him, but guess which Canadian income tax department sent me stuff they were supposed to send him?

5. @Eric
   “…Of course no one who “fled the Trump regime” is in this list.”

   Yes we are.

   I renounced early January and am on the list. I think things are only going to get worse for expats under the trump regime, I did not want to wait to find out what’s in store.

6. It was suggested to me by more sympathetic homelander acquaintances to wait for the tax reform proposal before renouncing. What’s laughable about this was they said “at least you’re in the system now” like this is supposed to be a desirable state. Of course what they meant was that I didn’t have to worry about the Fatca letter exposing me later on.

   This was unacceptable to me. Once you are tax compliant (especially after blissful unawareness), there is immense pressure to renounce in order to live a normal life. Those not in the system can manage too. It is only the ones that enter the US tax system and try to live in the system that are punished.

   I would imagine that there are some like me on this list. Caught up on filing after the OMG moment solely with the purpose of renouncing.

7. Actually correct from the above, what was suggested to me by homelander acquaintances was to wait for the outcome of the election in the hopes of seeing tax reform if Trump won. I renounced before the election results.

8. @UKRose, I completely agree that it’s the expats already in the system or who enter the system to become tax-compliant who are punished. The deal breaker for me was the fact that I would face huge ongoing accounting fees and burdensome paperwork.

9. @monalisa
   Yes it was the same for me, too much ongoing accountancy fees and lack of education of the US tax system played a part because I spent my whole adult life in the UK and didn’t plan my financial life around being a tax complaint US citizen. I would not have invested the way I did otherwise.

   Plus I have signage at work and was creeping closer to the exit tax threshold which isn’t hard to do in London with London house prices. Too much risk for me to play the wait and see game. You never know if things get worst too.

10. @UKRose

    I would imagine that there are some like me on this list. Caught up on filing after the OMG moment solely with the purpose of renouncing.

    Congratulations! Some like you? I would say very many like you, certainly those who started Brock and continue to work so there are a lot more. Every renunciation makes my day!

11. Thank you for this, Eric, and congratulations to those who’ve made it on the most recent Liberty List.

    Renouncing without compliance is the ultimate one-finger salute to a government that deserves nothing more. I hope they are plenty. There’s power in numbers.

12. @UKRose, exactly. I have spent all my adult life here in the UK and had arrived in my early 20s as an Art History student…I’d shortly thereafter met the man who was to be my husband, a native of London. I hadn’t been properly educated about the U.S. tax system so didn’t plan my financial life around being a U.S. tax compliant citizen. I wouldn’t have invested the way I did.

13. I certainly would not have sold my home in Canada without finding some legal way to avoid paying the US a dime in tax!

14. @Bubblebustin, I realize it was quite a shock for you. I’m sure many who’ve been hit with large tax bills had been unaware of the savings clause in the tax treaty that allows for double taxation as though the treaty didn’t exist. Many were and are oblivious to PFIC taxation issues via locally owned mutual funds or cash value insurance plans…many are unaware of potential foreign grantor trust issues or gift tax issues.

15. Another issue is the fact that low earners or pensioners living solely on passive income could suffer the narrow windows of being hit with US tax because the personal tax allowance can sometimes be more generous in the UK, at least.

    The first £11,500 of income is tax free, plus we enjoy an annual tax free allowance of £1000 on interest and another £5000 annually in tax free dividend income…plus ISAs. The IRS might start accusing the UK of being a tax haven!

    The very rich pay far more tax though than in the US. It’s why the wealthier expats can offset US taxation via foreign tax credits on form 1116. The rich also can afford boutique portfolio management via individual stocks and bonds, whereas pooled investments such as mutual funds are used more by the ordinary middle classes.

    Seems there’s a two-tier system that looks after the rich and penalises the little man who tries to get ahead.

16. @monalisa – “Another issue is the fact that low earners or pensioners living solely on passive income could suffer the narrow windows of being hit with US tax because the personal tax allowance can sometimes be more generous in the UK, at least.”

    That’s exactly what tax accountants and compliant expats assured me would be my fate, when I first heard of CBT and started trying to find out what was what. They spoke in vain, because it was obvious to me from the start that paying US tax on my UK-taxpayer-funded pensions would feel to me like embezzlement, which I was not going to do.

    After long weeks of digging, and arguments about the wording/meaning of the tax treaty and various IRS publications, I concluded that my pensions were probably exempt under the tax treaty, therefore should be excluded from my gross income; and since that brought my US-taxable income below the threshold, and 8833 reporting is waived for pensions, I filed no 1040s, just the 8854.

    I mention that wken the opportunity arises, just in case it might be of interest to anyone in similar circumstances.

    The IRS has shown no interest in questioning my interpretation of the tax treaty.

17. @monalisa
    My situation exactly mirrors yours, came to the UK as a university student age 19, met and married an Englishman later on, Also lived in blissful unawareness of US tax laws until recently.

    @Bubblebustin
    Yes it’s so easy to fall into this trap. It could have easily happened to me with my first property because my spouse and I lived there first before buying something together but I decided to hang on to it and buy the second property with my spouse without selling the first. and what makes me angry is that we have to prove our non willfulness when just looking at how people have handled their affairs is enough proof. People who know the US rules plan differently.

    @Patricia Moon
    Yes it was such a relief to renounce. I handled the situation with a realist mentality from day one without sentiment. Finding this website was a godsend especially to learn the true facts.

    @all – renounce while you can with or without compliance or stay under cover, as of today these are the only two options that allow a normal life. I hope this changes.

18. There is no chance of staying under cover anymore. Renounce while you can and get out before they pass some other absurd law to make it impossible for you to renounce. Myself I am regretting now why I did not renounce when there was no fee for renouncing and less headaches. Just to see my children who could have come here to see me. US citizenship is not worth the headache anymore as banks and brokerages are not welcoming US citizens no matter if they pass SCE or not. It is CBT and FATCA repeal which will never happen as compliance condors will never give up,

19. “There is no chance of staying under cover anymore.”

    Millions of non-US-resident USCs never file.

20. UK Rose & monalisa: “It is only the ones that enter the US tax system and try to live in the system that are punished.”

    I agree with you as far as direct financial punishment goes. But there are other forms of punishment that affect some of the rest of us. My situation is such that I cannot comply and I cannot renounce. Therefore, unless CBT is scrapped, I am doomed to live out my remaining years in a state of perpetual disobedience to a United States law. I was once warned by a US consular official to be aware that when travelling to the US as a dual citizen I should be mindful of obeying US law because, if I were to get into trouble, the Canadian government would have no right to assist me. Therefore my punishment is exile … permanent unless CBT is abolished.

    I have not seen the land of my birth for six years and I am unable to fulfill my parents’ final wishes. For me, this is punishment that is very hard to bear, particularly when my “offence” was nothing more than ignorance of a law that I would never have thought even existed.

21. Remember that there are the U.S. “allowances” known as the “personal exemption” and “standard deduction” that keep your income from being taxed from the first dollar (in most cases – but living abroad does not disqualify you though, so they still apply here).

22. I’m on this list, too; renounced Q4 2016.

    Eric, thank you again for another excellent analysis.

23. Renunciation ends both FATCA and CBT, but many who would like to renounce cannot afford to do so. Have there been any efforts by any group towards helping people get rid of US citizenship more easily than is the current situation?

24. Kelly, that may be true but many US citizens outside USA have never been tax compliant or stopped filing when they left. It is not cheap or easy to enter or reenter the US tax system. It makes more sense for people who permanently live in a different country to renounce US citizenship, thus my question about whether anyone is pursuing a way to renounce US citizenship without having to enter the US tax system first.

25. @iota. Not everone is lucky as you are to be living in Canada. Lots of people all over the world are getting forms to file if they are US citizens or not. Millions of Indians had to sign the forms certifying they are not US citizens or permanent residents or risk bank account being frozen . It is all over the news. Please google for it. You are lucky to just tick off Canadian resident and be done with it but there are plenty of people all over the world who could not check resident box since the form only asked if you are US person please check this box under penalty of perjury. I am not from India but I was reading yahoo a few weeks ago and this was headline news that I read when I woke up. 1.5 million Asian Americans are having this nightmare too and thinking of renouncing as I was reading this news. All banks overseas are advised to look for any US indicia and report or be penalized. I was told by a bank manager and brokerage both not to open up the account if I was going to check the US citizen box as their compliance teams will automatically pick it up and deny the account. Thank you US govt for giving us all a wonderful gift and I pay all my bills using cash now.
    FYI, all of you who are living in Canada should be glad to be living in Canada as its still better than living in countries where you get only one box to tick whether US citizen or permanent resident or not. Check the other box if you are not from US. Then simply they will ask you to close the existing account as they don’t want US citizens in fear of retaliation by US govt of fines. When you make laws like that can you really blame the banks only? CBT should have gone decades ago but it was decided to keep it to milk its citizens as much as they can and the biggest prize of course was the banks themselves to fine.