The Federal Register published expatriates list for the first quarter of 2015 is finally out for public inspection and due to be printed tomorrow, more than a week late. The IRS approved the list for publication internally on 28 April and sent it to the Federal Register folks, but it was not actually published on time, a clear violation of 26 USC § 6039G(d). However, this is barely even news: the list has been late for nine out of the past ten quarters too. And anyway one week is far short of the record of 599 days set by the Q2 1998 list (which didn’t appear until March 2000), or more recently the Q2 2010 list, which was 103 days late. Such habitual tardiness clearly indicates that this is a willful violation of the Internal Revenue Code by IRS employees, which should be punished but certainly won’t be.
This list contains 1,336 names of certain people who renounced or relinquished U.S. citizenship and whose information the IRS received in the first three months of this year. This is a smaller number than the 1,406 records — solely of renunciants, not of relinquishers — which were added to the FBI’s NICS gun control database over the same period, bringing it from 27,240 renunciant records up to 28,646. NICS also added another 767 renunciant records in April. (Given that the Federal Register list is too small even to cover all renunciants, it is not mathematically possible that it includes ex-green card holders, and no name of an ex-green card holder has ever been confirmed present in the list.)
This late, incomplete list isn’t merely a source of mild annoyance for us here at the Isaac Brock Society — instead, for the second time in recent years, it’s causing political controversy in the Caribbean. Haitian First Lady Sophia Martelly states that she renounced U.S. citizenship in March 2014 in preparation for her own entry into electoral politics this year. Local newspapers have complained that her name hasn’t shown up in the Federal Register list. But this isn’t unusual at all: nearly every single other public figure I know of whose 2014 renunciation/relinquishment was reported in the media hasn’t shown up either.
