This post about Sir John Templeton appeared on the RenounceUScitizenship blog. In an earlier post I suggested that by renouncing U.S. citizenship Sir John Templeton was able to use his wealth to benefit humanity. The media is prone to depict Templeton as a tax cheat. The reason? Had he been a U.S. citizen when he died, the U.S. government would have received approximately 100 million in estate taxes. This post considers this claim. I am not aware of Templeton ever publicly stating his reasons for renouncing U.S. citizenship. Nobody knows for sure. But, I suspect that the correlation between his renouncing U.S. citizenship in 1964 and the enactment of the CFC (Controlled Foreign Corporation and SubPart F) rules in 1962 did play a role. To put it simply:
The 1962 changes in the Internal Revenue Code meant that Templeton may have been forced to choose between U.S. citizenship and his mutual fund business. This is not much different from the situation of Americans abroad today. Again, I emphasize that this is pure speculation on my part. But, if you agree you will see that Templeton may have been forced to renounce U.S. citizenship. It is very clear that U.S. tax laws make it very difficult for individuals and corporations to participate in a global world. Sir John was one of the earliest casualties of this reality. Citizenship-based taxation continues. FATCA is the most recent manifestation of this principle.
Message to all you Homelanders: If I am correct, it was very costly to the U.S. government to have forced Sir John Templeton to renounce U.S. citizenship. Just one more example of how costly citizenship-based taxation is to the Homeland! But, again I am just speculating.
