93 thoughts on “1,376 published expatriates in Q3 2017 Federal Register list of people giving up US citizenship”

1. Just read Virginia LaTorre Jeker’s flippant comments about renunciation of US citizenship. I did try to comment on her article, but it was not accepted. I’d like to think that’s because many others have posted critical comments, and the columnist has put her virtual hands over her ears to keep from hearing any more; but it may just be a technical issue.

   This tax advisor has in the past made some helpful comments and provided some useful information; but I guess all these tax-industry people tend to panic and lose their good sense a little, at the sight of potential clients renouncing – paying the DoS for a CLN instead of paying the tax advisor to make sure the US tax handcuffs have been put in place correctly.

2. @plaxy

   Some condors actively encourage renouncing – there are big gains to be made there, especially when you throw in 5 years of tax compliance. Up until recently, one Canadian firm claimed you couldn’t renounce without being tax compliant. I wonder how many would not have gone to the expense of tax compliance just to get a CLN before they corrected that misstatement. Maybe not so many in Canada, because banks aren’t closing accounts of US persons without CLN’s.

3. Yes I’m sure it must happen a lot. But perhaps as it’s become common knowledge that compliance isn’t necessary, maybe condors find that their incomes are going down while renunciations are still going up. There’s one who crouches in a forum I read – he has begun to sound positively agitated as he warns posters again and again of the hazards of non-compliance.

   Lately, it has seemed to me that Ms LaTorre Jeker was sounding increasingly uneasy. I may have imagined it.

4. Waiting to hear from IRS Medic about the Tax Cut and Jobs bill. Maybe it should be called for expats the “Cut Tax and Jobs” bill, as while it is written will surely DESTROY our livelihood.

   IRS Medic has taken the stance that TTFI would be good, but they are the outlier unfortunately.

   I just got an update from RO this morning. It’s a call to not give up even though TTFI was not included in the bill. Considering the bill contains proposals that would destroy my livelihood in Canada, I cannot give up. It can go either way at this point, and I suspect the condors know that too. Their job is to make things look so dismal that you should spend thousands of dollars on compliance to renounce because things will never change.

5. Here is the update from RO today:

   Dear Suzanne,

   House Republicans introduced the tax reform bill (H.R. 1 – Tax Cuts and Jobs Act) on November 2, 2017, and overseas Americans immediately reviewed it to see if Territorial Taxation for Individuals was included in it. After Chairman Brady mentioned TTFI in a press conference and stated that his committee was seriously considering it, expectations were high. Unfortunately, this first version of the bill did not propose TTFI. While we are disappointed, this is not entirely unexpected. The process of getting a bill introduced and then voted into law is a complicated process that balances many competing requirements.

   The tax bill does support a move to territorial taxation for corporations, and this is a positive development for overseas Americans. Moving away from a corporate version of CBT paves the way for moving away from CBT for individuals as well. Nothing in the tax reform bill’s language regarding territorial taxation for corporations would negatively influence or prevent a change to territorial taxation for individuals.

   While not yet included in the bill, our TTFI proposal is currently in the Joint Committee on Taxation.

   Furthermore, the complicated nature of marking up a bill and reconciling it between the House and Senate also means that there are still several points where TTFI could be introduced.

   “We are confident that our friends of the House Ways and Means Committee will do their best to get our TTFI included in Chairman Brady’s mark-up. When we started fighting for TTFI in January of this year, nobody on Capitol Hill said that TTFI inclusion would be an easy fight,” said Solomon Yue, Jr., CEO and Vice Chairman of Republicans Overseas. “We’ve made progress and have gotten senior officials talking about TTFI. Now we need to get those words put into writing in the tax reform bill. We are committed to fight and win this uphill battle.”

   If Chairman Brady’s mark-up does not contain any language on TTFI, then the next opportunity for including TTFI in tax reform will be in the Senate’s version of the bill. We may have an additional opportunity to lobby in person for inclusion of TTFI in the Senate bill, and we will let you know when that happens.

   The fight to end double taxation is not over—we are still fighting for TTFI inclusion, and we will keep you updated on developments. The strongest weapon we have to fight for TTFI is grassroots support. As a result, please keep gathering signatures on the petition: http://ttfi.info/.

   Sincerely,
   Michael DeSombre
   Worldwide President, Republicans Overseas

6. To be honest Bubblebustin, the prospects for TTFI don’t look great, to me, but on the other hand I don’t think Max Reed’s interpretation is likely to happen either.

   I think they’re going to have a lot of problems getting a bill through at all – the same problems they had with trying to repeal/replace Obamacare, only worse because an election is looming.

   I’m still optimistic that FATCA harm might get reduced by changes to the regulations.

7. “While not yet included in the bill, our TTFI proposal is currently in the Joint Committee on Taxation.”

   What does that mean I wonder. I looked on the JCT website (https://www.jct.gov/about-us/role-of-jct.html)
   and came away not much wiser although it’s interesting to learn that the JCT attends the House markup hearing and provides running estimates of revenue consequences as provisions are changed or dropped (or added?)

8. “The tax bill does support a move to territorial taxation for corporations, and this is a positive development for overseas Americans. Moving away from a corporate version of CBT paves the way for moving away from CBT for individuals as well. ”

   It doesn’t really. Since the US is the only large economy that has CBT for individuals on its books, moving from worldwide to territorial for corporations has never yet paved the way for a move from CBT for individuals to TTFI, and there seems to be no obvious reason why it should.

9. Unless of course not going to TTFI or RBT stands in the way of TTFCorporations somehow?

10. One thing that makes me uneasy about the tax reform bill is that Section 911 would get a cross-reference from Section 1 (for the definition of “unearned income” in some provision about shifting income to kids). That means:

    1. Section 911 is probably going to stick around – but 911 shouldn’t be necessary under TTFI
    1. Because it’s cross-referenced from the very first section of the code, Section 911 becomes a lot more salient and politicised, and more clueless folks will try messing with it without understanding how it affects the diaspora

11. “Unless of course not going to TTFI or RBT stands in the way of TTFCorporations somehow?”

    That would be very good news.

12. @Getout
    If you have had no email response from your consulate about your wife’s CLN, then I suggest you call the State dept . Others have done this in the past and seems to get results.
    https://www.state.gov/documents/organization/112065.pdf
    I believe the number for German affairs is 202 647 5020 ext 5218. You can check the link above.

13. @getout

    I was surprised, too, that it went so fast. Mine took 8 months to get approved, then another month to get to me.

    For the record (if someone want to put this in the list):
    It took him about six weeks from the first mail to actually getting an appointment in Frankfurt. Had to play the same stupid games I had to, with no answer, then vague instructions, then no answer, then wanting the statement of understanding pre-signed, no answers. However, when he finally got someone on the phone after another week of it not being answered and the central number just saying no one was there without saying when someone would be, he got an appointment for in just less than a week.
    Appointment was on 19.09.2017. At least this was (supposedly. I wasn’t there and I’m not going to go asking too much) just a straight-foward pay, say oath, sign, half-hour slam-bam-thank you (for your money) ma’am interview.
    The switched CLN came on Sa. 28.10.2017. We sent it back collect on the following Monday and his correct CLN came on 04.11.2017.
    I’m not sure what the approval date is because I only got a short look at it, but the time frame is so short, it doesn’t really matter.

    BTW, for those who know how hard I had it when it came to how to tell him he needs to do it. Well, i warned him that I something to say when he finished school, then when the time came, he listened to what I had to say (just the once), said ok, and did it. I wasn’t to talk about it before, during or after the process. But he did it without putting up too big a fuss.
    No that that’s done, we’re done with the US in this family. Forever.

14. @UnforgivenToo

    Thanks for the details. My wife’s appointment was about 2 weeks prior to your son’s, but still nothing in the mail. My wife emailed the Consulate, but – of course – no answer. I really wonder what causes them to not process these things in order received.

    Other than that, the process for my wife was as you described. They were very slow answering initial inquiries and insisted on a copy of the German Einbürgerungszusicherung (guarantee that the Germans would grant her citizenship once she gives up the American one) ahead of time. However, it took my wife over two months to get an appointment at the Consulate, which suited us fine since we had some travel plans prior to that. In the emails from the Consulate, it mentioned various processing times for the CLN, sometimes it said 2-3 months, sometimes it said 4-6 months. I think they don’t bother to update the drafts which they copy and paste. At the interview, however, she was told 6-8 weeks. Her case is very straightforward, born in the US with only one nationality, now lived in Germany for almost 10 years, married to a German citizen forever, filed all her taxes.

    Anxiously waiting …

15. Hang on to the receipt. You can show that to a bank to show them that you did renounce and are waiting for the CLN – a “reasonable explanation.”

16. The Independent is running the Bloomberg story
    https://www.independent.co.uk/news/world/americas/american-citzenship-renounced-record-rate-treasury-department-a8040311.html

    Posted on various social media
    https://www.reddit.com/r/politics/comments/7b8b4r/americans_renouncing_us_citizenship_at_record/
    https://twitter.com/Independent/status/927551848831176704

    I wonder if Raphaels Bank has any opinion about the last line of the article
    https://twitter.com/raphaelsbank

17. @getout
    Did you see my post above with link to telephone numbers in the State Dept?
    A call often expedites the cln, especially if you emphasize she is now stateless and without any passport until it arrives.

18. @Heidi

    Yes, thank you. I gave the numbers to my wife, she’s going to try and call there today. I’d be surprised if they actually answer the phone, but it’s worth a try. It worries me that two people who renounced in the same Consulate after my wife already got their CLN’s. Relative to them, my wife is about 3 weeks behind.

19. “I wonder if Raphaels Bank has any opinion about the last line of the article”

    I’ve lost all sympathy for John Quitter after reading his CV. I wouldn’t be surprised if Ms Woolley knew exactly who she was taking a pop at.

20. The stream of garbage articles about the list never ends
    http://www.refinery29.com/2017/11/179923/us-citizenship-expatriates-foreign-account-tax-compliance-act

    Yes, the political divide may be one reason for people to say that they’re ready to pack it all up and live abroad, but in reality, it could boil down to financials and a pesky thing called tax evasion.

21. Obviously tax evasion is the reason for moving from a low tax country to a high tax country.

22. @ Plaxy @ Bubblestein Not all accountants and lawyers are encouraging compliance or even renouncing… I am aware of several individuals with businesses who were told if they had no Social Security number, no US passport, no US ties, not to expose themselves. They also told them they’d stay home and avoid travel to the US, wait for tax reform.

23. Thanks Ann#1. Glad to hear it.

24. Well they (the lawyers and accountants) are going to look pretty bad if things get worse for us.

25. Wu Cheng (吳崢) is in the process of renouncing US citizenship to run in next year’s Taipei City Council elections
    https://udn.com/news/story/6656/2813736