Renunciation and Relinquishment of United States Citizenship: Discussion thread (Ask your questions) Part Two
Ask your questions about Renunciation and Relinquishment of United States Citizenship and Certificates of Loss of Nationality.
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NB: This discussion is a continuation of an older discussion that became too large for our software to handle well. See Renunciation and Relinquishment of United States Citizenship: Discussion thread (Ask your questions) Part One
This showed up today via twitter.
https://docs.google.com/file/d/0B7VqDyDIAgW2YTQyQmZ3QjZyT2s/edit?pli=1
http://blogs.angloinfo.com/us-tax/2014/10/12/tax-court-affirms-informal-relinquishment-of-green-card-not-enough/
The Department of Homeland Security has provided statistics pursuant to a Freedom of Information Act (FOIA) request regarding the number of green cards surrendered each year since 2000 as evidenced by submissions of Form I-407 (discussed below). I provide here the numbers of green card relinquishments since 2010, when FATCA was enacted:
2010: 19,545
2011: 17,267
2012: 17,775
2013: 11,185 (queried on June 20,2013)
At first glance, it shows the opposite trend. However, the 2013 data is only for half (or less) of the year.
I believe it shows that the Federal Register is incorrect, as it is meant to reflect loss of greencard (as explained in the wikipedia article)
https://en.wikipedia.org/wiki/Quarterly_Publication_of_Individuals_Who_Have_Chosen_to_Expatriate
Hello,
Not exactly an expatriation topic but related; please allow me the following sad story.
Have lived overseas with my wife for nearly 30 years, have done what I thought was the right thing by consciously filing tax returns and FBARs. Where I live access to US tax advice was nonexistent, I relied upon the old IRS guide for overseas filers in order to file my returns and until 7-8 years ago only had a 28.8 dialup connection for internet access. Modest income, just to give you an idea we easily meet the 8854 income and asset tests even without joint/community property apportionment. An elderly family member is in need of us to act as her power of attorney. With all the hoopla about FACTA, FBAR/Fcen a little investigation indicated we would be liable for penalties if we missed reporting any of her financial assets. How could we take on that risk?
So for that and other reasons, we started the process to expatriate. Expatriation might get us out of the FBAR/Fcen reporting issue but wouldn’t do anything about alleviating the ever increasing burden of filing US tax returns unless we could be “not covered” as determined by 8854. As I mentioned we easily comply with both the income and assets test but how about attesting to being in tax compliance for the last 5 years – easy I told myself after all I have been filing as required for 30 years.
In preparation for renouncing our citizenship started reading the copious information posted by the gods John and Phil on their respective websites. Everything looked good and then I saw some information regarding form 3520A – basically lots of people don’t know they were/are required to file and that the penalty is $10,000. Humm, the retirement plan here is government mandated, employers are required to contribute, management of the plans are regulated, tax treaty with the US makes distributions non-taxable, IGA excludes plans from FACTA reporting – so qualified plan right? Well apparently not the case (according to a 2008 IRS ruling I just found) and of course I haven’t ever filed 3520A. Now, that then pointed to the requirement for the mandatory employer contributions to be reported as personal income and that income would not be covered in the earned income exclusion. I haven’t been doing that… In addition the FBAR/Fcen exclusion for qualified plans apparently wouldn’t apply either requiring reporting,, haven’t done that either… I have been reporting distributions, both on the 1040 and on 8938, even though a tax treaty makes them non-taxable.
We are nearly 70 years old. When I said modest income the total in the retirement plans would be in the order of $400k. We depend upon the modest distributions. Now I’m faced with what looks to be tens of thousands of dollars in penalties, back taxes on the employer contributions, and perhaps/probably a “willful” penalty outright loss of half our retirement savings. Then on top of that FBAR/Fcen penalties of what tens of thousands more dollars? That would pretty much end up taking the entire balance in the plan and maybe even more.
I’ve let my family down. At my age even if I could find work there would be no way to recoup what will be taken away. When there’s no hope it seems pretty hard to know where to turn, what to do. Too late to take out a life insurance policy and besides I’d die a US citizen and owe more tax. The sad part is over the last 30 years I spent hundreds of hours filling out tax returns genuinely believing I was doing the right and correct thing all along. The _really_ sad part is what I’ve done to the family. I’m pretty depressed. 🙁
Sorry..
SadOne,
Your story and many like yours are indeed sad stories. I don’t know the country you live in, but here in Canada Alliance for the Defence of Canadian Sovereignty has launched a legal suit against the Government of Canada for signing an intergovernmental agreement and legislating its implementation in Canada to override Canadian laws and the Charter of Rights and Freedoms. Our website is http://adcs-adsc.ca/. There is also a legal suit started in the US.
We are being criminalized for our ignorance of US tax law while we have made our lives in other countries. The US did nothing to “educate” us — and if, like me, your education was in the US, you likely never learned anything about what US citizenship-based taxation was even there. That is the problem — CBT vs logical and more fair residence-based taxation of all other countries, save Eritrea (and it is condemned for that by the US) and our residual US citizenships. For your family, for mine, for so many others, I can never forgive the country of my birth.
I hate that you feel that you have let your family down. It is a common feeling though. Please stay tuned here for you will get support of many who understand what you are now going through. You will also likely get some good advice, which I am not capable of giving you.
Sad one. Stop! Whoa! Slow down! Go ahead and renounce. Ignore the 3520 and 3520 A . It was not possible and is not possible for you to file them. There is no way for you to acquire the numbers required as they don’t exist. Repeat ignore them. You did your best to comply. Nothing bad will happen.
@Atticus, I know I’m a bit late to mention it but am so pleased for you that you’ve FINALLY received your CLN after OVER a YEAR. You must feel so relieved….
@calgary411
Thanks for the words of comfort. My most sincere sympathies to others who have experienced similar situations and had similar feelings.
@Duke of Devon
Would you consider an off forum discussion?
**MODERATOR**
Please give Duke of Devon my e-mail address
** **
Looking for anything to pick myself up, I’ve gone back and re-worked the last five years of tax returns – added the employer retirement plan contributions as income. If I were to file amended returns it turns out that there would only be tax due, a few hundred dollars, for last year with no addition tax due in the remaining four years. Wondering if I should at least clean that bit of the mess up?
Sad One, Are you a trained tax professional? If no, you do not know if you did things correctly or incorrectly!!!
To the best of your knowledge have you complied? Has someone trained told you that you are not in compliance?
If you filed and filed based on good faith, then you are done unless the US tells you otherwise!! You will go nuts reading and reading again the forms and publications and tax treaty.
If at some point you are audited, the US may or may not tell you that you them some money. Only they can tell you what the status is.
If you owe the US money, do you live in a country that has an agreement to assist in collection? There are five countries that have an assistance agreement.
To be honest the attitude I took in the past when I was a USC, was to follow the rules to the best of my ability and understanding and NOT paying thousands to the compliance industry to either save me or get the US Government an extra hundred dollars.
@Sad One, “If I were to file amended returns it turns out that there would only be tax due, a few hundred dollars, for last year with no addition tax due in the remaining four years. Wondering if I should at least clean that bit of the mess up?”
Look up the statute of limitations, you are concerned if its under the statute of limitations.
First decide if you are going to renounce, get that decision made. Then schedule the appointment. Amended no tax returns are secondary to this.
Then RENOUNCE.
Keep filing each year to the best of your understanding and capabilities until you get your CLN. To be honest, I do not think your analysis on if you need to file another form is right or wrong. But it is good you did estimate the possible tax and since its zero or token the government will not care.
Once you get your CLN, then decide which years MIGHT need to be amended and then decide if it is appropriate and how sure you are as a non trained person if it needs to be amended.
Just to show you screwed up these rules are. In my country I went to the tax office to register and asked them about the US. A senior tax officer at that office told me after pulling out the US/______ Tax Treaty that if I had no US income, there were no US filing requirements for a citizen of _______ living in ________ .
A problem with Brockers is reading too deeply into the rules of a foreign government and getting all stressed. Do your best based on what you know and then hand in the blue book.
Sad One.
PRICELESS !!!!!
Modifying prior returns is pointless. It merely raises a flag.
P.S. Mods don’t have my e mail. Give me a day or 2 to set one up and then I’ll contact you. Cheers Duke.
Moderators. You can send me Sad One’s email at this gmail account.
@ Sad One.
As usual, the Duke and George have nailed it. One clarification re: George’s “Keep filing each year to the best of your understanding and capabilities until you get your CLN.” You only file up to the date you lose your US citizenship. The procedure is well documented here and elsewhere.
A renunciation, unlike a relinquishment, is a slam dunk. You will get that CLN, eventually. But you file 8854 and your last tax return by the normal due dates, regardless of whether you actually have that CLN in hand. No need to prolong your agony into another tax year merely because you are waiting for an extremely slow bureaucratic process. Take control; do it on your schedule, not theirs.
Sad One, you have been given some very, very good advice here. I’d slow down and do your best, THEN get that CLN if that is your decision. Don’t let something drive you crazy because it will and not even the best accountants out there tell you everything correctly. I even had IRS telling me every single year that I had not met the requirement to have to file while NOT mentioning FBARs at all even after I questioned them extensively saying “So you are saying I am good with you? There is nothing else I need to know or do?” REPEATEDLY I asked this question year upon year so imagine my surprise when I found out that indeed I needed to file FBARS for some of those years, a paper I had never been told about, had no way to know if IRS was giving me incorrect information.
@Mona Lisa, thank you especially. I know what a difficult process this was for you too! I think of your journey often as the emotional process was similar to mine.
An email from Phil Hodgen that seems to me a good summary for those looking for answers to the question about social security numbers, or lack thereof, and expatriation.
He writes:
This is a multiple “Yikes” edition of the weekly Expatriation news. One “Yikes” is that it is late. This has been a travel week in the Middle East for me. At the moment I’m sitting in the lobby of the Burj Rafal Kempinski Hotel in Riyadh on a Friday morning and somehow the week got away from me without sending out the Tuesday edition.
Sorry. Tuesday comes on a Friday this week. Next week, Tuesday will revert to its normal schedule.
This week’s question
My agenda this week includes meeting with a lot of people in Riyadh who are thinking of giving up their U.S. citizenship. For some people it is an easy decision, and for others it is painful. Tears-in-their-eyes painful.
Here’s the problem they face. I will cobble together a question because I have had this conversation with a lot of people this week:
I was born in the United States but my parents brought me back to Saudi Arabia when I was two months old. I have lived here ever since and never applied for a Social Security Number. Now I want to give up my U.S. citizenship but I know that there are lots of tax forms to file. How can I do this without a Social Security Number?
The short answer? You almost certainly want to clean up your prior year tax nonfiling. The only question is whether you do this before or after renouncing your citizenship.
If the tax cost of covered expatriate status is too high, get the Social Security Number, then fix the past, then renounce.
If the tax cost of covered expatriate status is low enough (like zero!), renounce, then clean up the past years.
Step By Step:
In summary
Know the three ways that you can be a covered expatriate.
1. Not filing your tax returns is one (and you haven’t filed if you don’t have a Social Security Number. The other two are that you are you too rich (net worth of $2 million or more), or you had a large Federal income tax liability for the prior five years.
2. If one or both the other two ways of being a covered expatriate apply to you, then it really doesn’t matter whether you expatriate without a Social Security Number and clean up your tax stuff after renunciation.
You are a covered expatriate.
3. If the other two ways of being a covered expatriate do not apply (your net worth is under $2 million and your average tax liability for the prior five years is under $157,000) then the question of fixing unfilled tax returns before expatriation matters a lot to you. It makes the difference between covered expatriate status and not covered expatriate status.
4. Now look at the tax consequences of being a covered expatriate. Does this trigger any exit tax liability? Pretend that you sold everything you own when you expatriate. Is the capital gain above $680,000? If so, you will pay tax for the privilege of renouncing your citizenship. Do you have IRAs and other strange Congress-created tax-advantaged accounts? Do you participate in pension plans? Are you the beneficiary of a trust? All of these might create tax liability for you when you renounce.
5. If you have decided that the actual cash tax consequences of renouncing citizenship is small enough for you to handle, then covered expatriate status is OK. You are going to expatriate first, then do cleanup. You will get an Individual Taxpayer Identification Number after renouncing and do a bunch of tax filings.
6. If you have decided that the tax consequences of being a covered expatriate are too high, you will get a Social Security Number first, fix all of your tax filings, and then renounce carefully, in order to avoid covered expatriate status.
7. For both of these choices, you will need to figure out how to clean up the past. The three choices are the Voluntary Disclosure Program, the Streamlined Procedures, or “just file”. You will do these either before or after renouncing your citizenship.
Covered Expatriate Status
Giving up U.S. citizenship has tax consequences. The tax consequences are trivial (you have only paperwork to do) if you are not a “covered expatriate”.
If you are a “covered expatriate” you have the paperwork to do, and you have the possibility of paying some income tax to the United States. In addition, if you are a covered expatriate you cannot make gifts to U.S. persons or leave inheritances to them without a massive tax cost being paid by the recipients of those gifts or inheritances.
Usually, you would like to avoid being treated as a covered expatriate.
There are three ways to be a covered expatriate. One of them applies here: you are a covered expatriate if you are not fully up to date with all of your tax filings and tax payments. (Go look at Form 8854, page 3, at the bottom of the page — question 6.) This is the “certification test” where you certify that as far as tax is concerned, all is quiet on the Western Front.
No Social Security Number + Renounce
If you do not have a Social Security Number, then you could not have filed your income tax returns. By definition you have not done everything you are required to do for tax purposes under U.S. law. If you renounce your U.S. citizenship, you will be a covered expatriate.
There is only one possible exception to this: you never did anything that would trigger any kind of tax filing obligation under U.S. law. You never had enough income to be required to file a tax return. You never owned the “wrong” kind of assets that would trigger a requirement to file a piece of paper. You never received a large gift from anyone.
But for everyone else, you were required to do something under the U.S. tax law, and you didn’t. If you renounce while that is not fixed, you will be a covered expatriate.
Renounce Without a Social Security Number
This means your decision is pretty simple. If you want to renounce fast, you will have to live with the fact that the IRS will treat you as a covered expatriate. So you need to figure out how painful this is. Here are the consequences:
-You are treated as if you sold all of your assets, and you will pay tax on the capital gain above $680,000;
-You have the potential for taxable income from a variety of other sources, such as non grantor trust, pension plans, and special financial accounts like IRAs;
-and U.S. persons (like your children) who receive gifts or inheritances from you will pay a tax on whatever they get from you.
So here is what you do. You look at your situation and see if any of this matters to you.
-Look at all of your assets and calculate the capital gain. If the total capital gain is less than $680,000, then you will not pay any tax because of that. [Reference for tax nerds: Internal Revenue Code Section 877A(a)].
-If you do not have any “specified tax-deferred accounts” (like IRAs), you do not have any tax liability that will come from that direction.
-If you do not have deferred compensation plans and you are not a beneficiary of a non grantor trust, then you have no tax problems from those directions either.
-If your kids are not U.S. citizens or residents, then you do not have a problem there — they will receive gifts or inheritances from you without having to pay U.S. tax for the privilege of receiving stuff from you.
If all of these things are favorable, you can safely expatriate as a covered expatriate. The major milestones in your action plan will be:
(1) renounce citizenship;
(2) prepare all your prior year tax filings;
(3) prepare Form W-7 to apply for an Individual Taxpayer Identification Number; and
(4) file stuff after going through the risk analysis I am about to talk about.
If Covered Expatriate Status Is Too Painful
If you go through that analysis and you decide that covered expatriate status is too expensive for you (and you figure out that covered expatriate status is avoidable for you), then you have only one choice: apply for a Social Security Number, wait until it comes, file your prior year tax returns, and then and only then renounce your citizenship.
Risk Analysis: Prior Year Exposure
No matter which method you use — concede covered expatriate status and exit before cleaning up your old tax returns, or clean up your tax returns first then expatriate — you will have to figure out how to clean up the past.
You have a whole bunch of years of non-filing that you probably want to clean up. The most important thing when you cut your ties with the United States is to cut them cleanly, so Uncle Sam has no future leverage over you.
Now you look backwards in time and find out what your tax, penalty, and interest exposure will be. If the IRS found you and told you to file everything, what would you have to file? And since you are late, what kind of penalties would the IRS throw at you?
This analysis varies from person to person. Everyone’s situation is slightly different. But you will be able to figure out whether you are at a low risk for penalties, or whether you have a high risk.
If you have a low risk for penalties (e.g., you have very low income, your bank account balances were low, and you are not required to file all of the silly forms that the IRS wants you to file if you are a partner in a foreign partner, or a shareholder in a foreign corporation, or you received a large inheritance or gift from a nonresident) then you can be pretty comfortable proceeding with the expatriation. If the worst possible outcome occurs, it will not be that bad.
The only question is how should you proceed with filing those prior year tax returns and other forms, and how many years should you file for.
If you are at a high risk for penalties, then you will want to figure out how to minimize that risk. I do not like the idea of “don’t file” because the “how will they ever find me and if they find me what can they do to me?” strategy ignores the fact that it is hard to make predictions, especially about the future. Government policies might change. Technology might change. Your personal life might change.
You want to fix things. But how? Stand by.
How to Fix The Past
The three choices you have for fixing the past years (and I do recommend that you fix the past) are:
-The entirely awful Voluntary Disclosure Program;
-The quickly evolving Streamlined Procedures that are starting to show bureaucratic arthritis, in an effort to eliminate penalties; or
-Just obey the law and file what you’re supposed to file, taking your chances on penalties.
Those three topics are little universes unto themselves. Sorry. Some other day we’ll talk about them.
For people who have minimal exposure to penalties, there is no reason to do anything more exotic than merely file a bunch of forms with the IRS.
For people who have done sufficiently bad things that the IRS might want to make a poster child of you (see Admiral John Byng, for example) the Voluntary Disclosure Program might be the plausible solution. There is a lot to be said for being able to get on a plane and go anywhere you want to, anytime, without worrying.
For almost everyone, however, you will be in the vast middle. The penalty risk is high enough to matter. But you’re a normal person. Now the decision is between “just file” and the Streamlined Procedures. My experience is that the Streamlined Procedure is a puddle of confusion moving toward bureaucratic calcification and procedural complexity (IRS entropy points in that direction), but at the moment it is a worthwhile choice for many people.
Not Legal Advice
This isn’t legal advice to you, of course. Would you make life-altering decisions based on a random email you got from some guy you found on the internet? Nope. Me neither. Go hire someone. March through the analysis and figure out what is best for you.
Next Week
Happy weekend wishes to you from Riyadh. Next Tuesday there will be another expatriation-related question and answer. Send yours in. Hit “Reply” and start typing. When you’re done, hit “Send”.
Phil.
PS…. if you want to sign up for Phils weekly email with expatriation questions answered, and some shameless promotion (which he does NOT hide) here is his blog. http://hodgen.com/blog/
Hi all
I renounced in February this year and still have not received a CLN! Notwithstanding a number of emails to the consulate, I get virtually nothing back other than “we’re looking into it”. What the hell do they have to look into? How difficult can it be to stamp a bloody document? Am I going mental or have I done something wrong whereby I wont actually lose citizenship?
@gsint, Hi
No, you’ve done nothing wrong. It just takes time, more and more time these days. They also had a computer failure earlier in the year so that’s probably delayed things as well. Delivery of CLN’s varies considerably. I think the shortest time reported was 2 weeks, but there have been cases going the other way where it’s taken 18 months or more.
I suggest you contact the State Department in Washington and see if they can enlighten you. It could be something as simple as the file has been “filed” and forgotten. As they have the final approval/stamp of the document they should be able to tell you where it is in the process. Just be glad you beat the fee increase from $450 to $2,350.
If you’re up to date with your US tax filings then get your 8854 form as ready as you can so that can be sent off in June next year to close out your tax obligations. And take comfort from the fact that, as of your renunciation date, you are no longer a US citizen.
@gsint
If you want the contact information for the State Department (it depends on what country you are living in) just address a comment here to @pacifica777 and she’ll probably repost it for you. I had it somewhere but it’s not at my fingertips. CLNs can take a long time but they always seem to come through eventually.
@ Gsint
You do not say in what country you live or have renounced at. I renounced in mid-April in the Toronto Consulate. Was told then to expect a 9 month wait but, to my surprise, it arrived in early September (less than 6 months). I think it may have to do with how busy the one or two people are at the State Dept who are working on the CLNs for people in a specific set of countries. If you provide your location, perhaps someone else can help to answer your question
@ LM
I live in London and renounced here at the London consulate. I was told that under normal conditions I should wait about 8 weeks. Now its been 8 months. I’m going to take one of the last responses to heart and try to contact the state department – my main fear is that the papers have been lost somewhere in the system and nobody has managed to tell me that
thanks
@ pacifica777
Any chance you could repost contact details for the State Department? I would like to get in touch with them to check what is going on with my renunciation. I renounced at the London consulate and have been waiting for 8 months! Any help in identifying where to go with this would be greatly appreciated!
thanks
@Gsint,
Sure. Europe Division Chief for Consular Affairs/American Citizen Services/Overseas Citizen Services, the dept which deals with CLN issuance, is Teresa Mendel at 202-485-6245.
Sorry, we don’t have e-mail addresses, but the phone and snail mail addresses are in the Dept of State phone book. You can access that directly at http://www.state.gov/documents/organization/112065.pdf
or through the sidebar under “Important Information,” “Dept of State Forms, Procedure Manuals for Renouncing/Relinquishing, Contact Info.”
There’s probably nothing wrong with your file, as renunciation is a pretty routine matter. Either your file’s bogged down in a backlog or somebody dropped the ball on it.
So far Europe tends to deliver more quickly than 8 months, so it’s definitely worth making sure they didn’t drop the ball and lose it in the system. That happened to a couple of people here, and once those people called DC, things moved quickly and they got their CLNs within a few weeks. Hope you do too.
@Gsint,
You might also be interested to have a look at the “Time Chart of Meetings and CLN Delivery Time” in the back of the Consulate Report Directory. It shows the length of people’s waits, arranged by consulate location.
Gsint, I waited 13 months. They really are backed up. The time chart Pacifica suggested is a good way to keep track of how long others are waiting. Long wait times are not unusual these days. They had a data base crash, they were already backed up with these before that even happened. It’s not easy to wait that long with your life on hold but, it will arrive. I wish there were some way to track your own case online so you can see for yourself “case still pending” or some such as writing to the consulate all they have available to them is to log in and see such for themselves and then tell it to you. You have been waiting 9 months? You can check with the consulate through email every few months but, it is possible you could wait 13 months just so you know. That’s not unusual these days.
Interesting note of the backlog of renunciation services in Canada and the increase in the fee to renounce, from a blog called DiploPundit (“DiploPundit was started in March 2008 by the pseudonymous Domani Spero, an obsessive compulsive observer, diplomatic watcher, and opinionator who monitors the goings on at ‘Foggy-Bottom’ (i.e. the State Department)”…….”The blog, which is unapologetically opinionated and occasionally edgy, has no/no official connection to the U.S. Department of State, the Foreign Service or any other branch of the U.S. Government.”…..):
See;
http://diplopundit.net/2014/10/10/us-ambassador-gets-on-reddit-notnot-nearly-as-funny-as-anonymous-fso/
…….”…….Yesterday, we got the following via the Burn Bag:
“CA [Consular Affairs] will publish a proposed rule on Thursday in the Federal Register raising the fee for renunciation of citizenship from $450 to $2,350. This will not be popular. Fee based on annual fee study and lack of common sense.”….”
“……….Anybody know where we can find a copy of CA’s Cost of Service Model (CoSM) study?
Apparently, dual citizens in Canada trying to shed their U.S. citizenship have created a backlog at the U.S. consulate in Toronto that stretches into the third week of January 2015.
In any case, Americans who will be upset by this change in renunciation of citizenship fee can contact Congress to complain about this. Their elected representatives, presumably will be super-helpful to the soon-to-be non-voters……”
Hi EmBee and Atticus
in Canada
Thanks for the info re mailing address for cheque.
I’m sorry I took so long to respond. Sometimes it’s hard to know just where to look for questions and answers.
I faxed my lawyer with info to be sent to the Dept of Homeland Security.
Hopefully it won’t take too long to become seulement canadienne! (solamente canadense?- I wish I could retain Texas citizenship!) Jen
may i ask:
1) do you keep your US passport between the time you renounce and when you get your CLN?
2) the new $2350 fee does not apply to relinquishment only renunciation, right? because I naturalized in another country a few years ago and so will relinquish not renounce US citizenship.