Liberty and justice for all United States persons abroad

The Isaac Brock Society

Why Treasury Should Exempt U.S. Citizens Resident Outside The United States From FBAR Filing

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Introduction

On April 26, 2024 I submitted a comment to the OMB arguing that the time had come for Treasury to exempt Americans abroad from the FBAR filing requirement. I published the comment in the form of a post at my citizenship solutions site.

All of the comments may be read here. The government’s “supporting statement” includes:

 

 

Most of the comments were submitted by or on behalf of U.S. persons living abroad. A few comments were received from financial and legal associations. The consistent theme in these comments was that the FBAR requirement for U.S. persons living abroad is unnecessary and burdensome. Some of these comments also suggested certain revisions to, or exemptions from, the regulations. The comments are summarized in the following five categories.

• Unnecessary for U.S. Persons Living Abroad:
• The FBAR requirements are duplicative of the FATCA requirements.
• Almost all U.S. persons living abroad, even those with modest incomes, must file the FBAR because the $10,000 threshold is too low.
• U.S. persons living abroad need financial accounts in their country of residence for practical purposes. Maintaining these accounts is not suspicious.

• Burdensome for U.S. Persons Living Abroad:
• There is confusion regarding the filing requirements for the FBAR, because the FBAR and FATCA requirements are different as they relate to the thresholds and types of accounts to be reported. This can lead to misinterpretation and filer errors.
• The FBAR penalty for filing errors is excessive.
• Foreign spouses are required to report their financial information along with the U.S. spouse living abroad.
• U.S. persons living abroad are not afforded certain professional and charitable opportunities because of FBAR requirements. For example, a company or a non-profit may not want to hire a U.S. person living abroad for certain financial roles, particularly those that involve granting the U.S. person signature or similar authority, because the U.S. person would be obligated to report on the company or non-profit’s financial accounts.
• It can be challenging to determine the highest account value for certain accounts, because the statements do not always provide that information.
• It is costly to hire a tax professional to assist with FBAR and FATCA filing requirements.

• Recommendations for Modification to FBAR Regulations:
• Remove FBAR requirements, and permit U.S. Government sharing of FATCA information.
• Adjust the FBAR dollar threshold for inflation. The initial threshold of $10,000 has not been changed in over 40 years.
• Exempt employees from reporting signature authority over, but no financial interest in, their employers’ foreign financial accounts.
• Maintain special rules for reporting limited account information on 25 or more foreign financial accounts for entities that are highly regulated.
• Eliminate duplicative reporting of foreign accounts held by global custodians.
• Revise the FBAR instructions to account for the ruling in Bittner vs. United States.
• Change the maximum account value to the account balance as of December 31 of the calendar year to eliminate burden.
• Articulate how FBAR reporting is highly useful to the U.S. government.

• Exemptions for U.S. Persons Living Abroad:
• Exempt U.S. persons living abroad from reporting the financial accounts in their country of residence.
• Exempt U.S. persons that have lived abroad for a long period of time.

• Estimate of Time to Complete the FBAR for U.S. Persons Living Abroad:
• Determining the maximum value of an account can be time consuming because the information is not always readily available on account statements.
• U.S. persons living abroad may have 15 to 20 accounts for practical reasons. For example, many U.S. persons living abroad have a checking account, a savings account, lines of credit, investment accounts, retirement accounts, and business accounts. With this many accounts, it may take such a filer well over an hour to complete the FBAR.

And concluding with:

These comments will be considered as part of FinCEN’s review of regulations and guidance required by section 6216 of the AML Act. As part of this review, FinCEN will evaluate ways to clarify FBAR reporting requirements and minimize burden to the public, while retaining reports or records that are highly useful in countering financial crime. FinCEN also intends to conduct, pursuant to the Paperwork Reduction Act of 1995 (PRA), additional assessments of the burden associated with BSA requirements, including FBAR requirements.

Note that there is no consideration of these comments in the March report on the status of the implementation of the AML Act. https://www.congress.gov/crs-product/R47255

Seeking your help!!

I am in the process of preparing a presentation called “The Life And Times Of Mr. FBAR” for a professional conference at the end of June. As part of the process of organizing my presentation I have been looking at things I have previously written. I found my comment/argument and created an AI generated podcast and slide show out of it. The podcast is linked to in the tweet below.

A slide summary of the podcast and article is here.

 

What follows is the April 26, 2024 submission …

 

Any thoughts/comments would be appreciated.

 

 

Why Treasury Should Exempt U.S. Citizens Resident Outside The United States From FBAR Filing

John Richardson

 

To Renounce Or Not To Renounce – How (If At All) Does The Lower Renunciation Fee Impact The Decision?

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On March 12, 2026 the State Department announced that the fee to issue a Certificate of Loss of Nationality would be lowered from $2350 USD to $450 USD. This was extremely newsworthy and was widely discussed in the blogosphere. There has been some speculation that lowering the fee would incentivize people to renounce. One person reported that, at least one consular officer expected an increase in the number of renunciations. It is too early to tell whether this will be true.

On March 26, 2026 I hosted a podcast with U.S. tax lawyer Virginia La Torre Jeker for the purpose of discussing what the lower renunciation fee might mean. The podcast ended up becoming a discussion of the pros and cons of renouncing U.S. citizenship. It also became a discussion of the “IRS Relief Procedures For Former Citizens” (discussed here) actually worked (and why that program is so beneficial to those seeking to be in U.S. tax compliance.

Listening to the podcast today, I realized that the most valuable part of the podcast was the discussion about whether or not to renounce.

That discussion included:

– a recognition that U.S. citizenship is a depreciating asset

– the issue of renouncing citizenship and ability to access the United States

– the problem of how the U.S. estate tax applies to U.S. situs assets owned by those who are neither U.S. citizens nor domiciled in the USA

– the U.S. 877A and 2801 Exit Taxes

 

For those considering renouncing U.S. citizenship, I think the podcast will be helpful.

 

John Richardson

 

The Clash Between The U.S. Citizen’s Constitutional Right To Enter The USA And The Requirement Of A U.S. Passport To Enter

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Introduction

Today Petros commenting here asked the following question:

 

“At the end of the day, nobody has a statutory right (with the possible exception of U.S. citizens) to enter the United States.”

I know border guards have asked me questions about my intention for returning to my own country when I was still an American, even asking where I was staying. These question imply that as US passport holder, I didn’t have a right to enter the country. Still I was never refused. Are there cases where someone who presents a valid US passport is refused entry? How about if they present a valid US birth certificate as proof of citizenship?

I suggest the following answers to Petro’s two questions:

1. Those presenting a valid (meaning unexpired) U.S. passport should not be refused entry to the United States; and

2. Assuming the right of a U.S. citizen to enter the USA, a U.S birth certificate should prove U.S. citizenship (absent renunciation) and therefore allow for entry to the USA. For that matter (as described in the post below) an expired U.S. passport should also be proof of U.S. citizenship. However, without an unexpired U.S. passport entry to the USA will not be “friction free”.

The complicating factor is INA 1185 -a law for the express purpose of controlling the travel of U.S. citizens – U.S. citizens are required to leave or enter the USA on an unexpired U.S. passport. The specific language of the law includes:

8 U.S. Code § 1185 – Travel control of citizens and aliens

(b) Citizens

Except as otherwise provided by the President and subject to such limitations and exceptions as the President may authorize and prescribe, it shall be unlawful for any citizen of the United States to depart from or enter, or attempt to depart from or enter, the United States unless he bears a valid United States passport.

In 2013 Eric wrote a brilliant post explaining the history of the the rule requiring that U.S. citizens enter and leave the United States on a valid U.S. passport.

Bottom Line:

Although U.S. citizens may have a constitutional right to enter the United States, the lack of a unexpired U.S. passport may make it difficult.

Consider the following thought experiment:

Two Canadian citizens live in Canada and have Canadian passports. One of the two citizens is also a U.S. citizen without a current U.S. passport or with no U.S. passport. Incredibly the person who is ONLY Canadian can enter the United States with only his Canadian passport. But, the other person is in violation of U.S.C. 1185 which requires the U.S. citizen to enter the United States with a valid U.S. passport. Sound incredible? Yes it is.

I discuss this in the following podcast:

The podcast is based on this recent post on my blog at citizenshipsolutions.ca

 

About The Expired U.S. Passport – Is It Proof Of U.S. Citizenship (Yes)? Can It Be Used As A Travel Document (No)?

John Richardson

 

Badger Comments On Dr. Laura Snyder’s Paper: “Can Extraterritorial Taxation Be Rationalized?”

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Badger Comments On Dr. Laura Snyder’s Paper: “Can Extraterritorial Taxation Be Rationalized?”SEAT "Stop American Extraterritorial Taxation" is an organization created under French law to provide education and advocacy about the reality and problems of U.S. citizenship taxation. It was founded in…

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-05-25T18:39:37Z

 

SEAT “Stop American Extraterritorial Taxation” is an organization created under French law to provide education and advocacy about the reality and problems of U.S. citizenship taxation. It was founded in 2020. Since that time SEAT has done excellent research, writing and advocacy.

In 2023 SEAT President Dr. Laura Snyder published a paper called “Can Extraterritorial Taxation Be Rationalized?”

Strongly recommend reading Laura Snyder’s paper. Here is the abstract:

Abstract

There exist multiple rationales for the U.S. extraterritorial tax system. The rationales seek to explain why overseas Americans should be subject to worldwide taxation by the United States.

This paper challenges those rationales: The allegiance rationale is outmoded and rejected by the U.S. Supreme Court; the benefits rationale has been discredited; the membership in U.S. society rationale is belied by the exclusion of overseas Americans from critical beneficial aspects of the U.S. economy, the U.S. tax system, and federal assistance; the “worth the tax cost” rationale disregards human rights and the realities of renunciation of U.S. citizenship; and the administrability rationale ignores that the administration of an extraterritorial tax system requires resources beyond those required to determine domicile – resources the IRS does not have.

Ultimately, all the rationales are theoretical. They do not confront the reality of the actual extraterritorial tax system in place today. They do not contend with the full scope and complexity of the actual system, or the system’s multitude of intractable problems and injustices.

 

Note: “This is an article published by the American Bar Association Section of Taxation in The Tax Lawyer journal in the Spring 2023 issue.”

Keywords: Extraterritorial Taxation, Citizenship-Based Taxation, Residence-Based Taxation, Citizenship, Expatriation, Exit Tax, FATCA, IRS, Human Rights, Equal Protection

On May 24, 2026 long time Brock commentator and contributor, Badger published the following insightful comment about Dr. Snyder’s paper:

Continue reading →

The “Interview” At Your Renunciation Of U.S. Citizenship Appointment – A Public Service Announcement

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The “Interview” At Your Renunciation Appointment – A Public Service AnnouncementI haven't posted at Brock for a while. Although I have some ideas for some interesting posts, I wanted to create a very short post about the renunciation interview. This isn't major and it isn't something you…

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-05-24T15:30:50Z

 

 

I haven’t posted at Brock for a while. Although I have some ideas for some interesting posts, I wanted to create a very short post about the renunciation interview. This isn’t major and it isn’t something you (probably) don’t know, but here goes …

Note that effective November 1, 2024 there has been a very significant change in the renunciation process which is reflected in the new DS-4079. Here is an earlier Brock post discussing this (in a minimal way):

New Renunciation Form And Processes For US Citizenship Relinquishment Effective November 1, 2024

“Some” thoughts on the interview …

 

1. Remember that by taking the oath of renunciation (assuming it is determined to have been taken voluntarily and with the intention of relinquishing U.S. citizenship), you will NO longer have the right to live or work in the United States. Your access to the United States will be based entirely on what country you are a citizen of. Canadian citizenship is the “Gold Standard” because Canadians can enter the United States with ONLY a Canadian passport. Many renunciants are citizens of “visa waiver” countries and may go through the ESTA process without actually getting a visa. Citizens of visa waiver countries may stay in the United States for up to 90 days. Obviously, citizens of certain countries will be required to obtain a visa to enter the United States. This should be one of many considerations in deciding whether you wish to take the oath of renunciation.

2. U.S. Immigration law does contain a section listing “excludable aliens”. Much has been written about the 1996 REED Amendment (which in theory can result in being excluded if renunciation was determined to be for the purpose of avoiding U.S. taxation). To date that has not been enforced in a significant (it’s not quite zero) way. The REED Amendment should not be a concern unless you tell the Consular officer in the renunciation interview that are taking the oath of renunciation to avoid U.S. taxation.

3. Those with a criminal record should seek legal counsel before making the decision to renounce.

4. At the end of the day, nobody has a statutory right (with the possible exception of U.S. citizens) to enter the United States.

5. At the renunciation interview the Consular officer is required to take notes, prepare a report along with a recommendation (allow the renunciation or not) which goes to the State Department lawyers in Washington, DC. This is the context in which the approval to issue the CLN is made.

6. Therefore, you should be thoughtful about what you say in the interview. Apparently, at least one person has been recently asked whether his decision to renounce was motivated by recent political events in the United States. Yes!

7. FYI interest, here are “some” other questions that people have been asked …

– are you renouncing because of U.S. taxation?

– what are your connections to the United States?

– do you have U.S. citizen children?

– has anybody been pressuring you to renounce, etc.

Note that the new DS-4079 includes a number of questions to determine your ties to the United State!

My point is:

The renunciation interview clearly functions as a way of documenting statements you make at the time of renunciation. You should be aware of this and (I think) be somewhat of a minimalist in your responses to questions in the interview. To be clear, the Consular officers are just doing their job. They are generally friendly. Their job is to make a determination of voluntariness and intention. That said, please remember that the contents of the conversation will (mostly) be documented and become part of your permanent file.

In conclusion:

To be “FORMWarned Is To Be ForeArmed!

John Richardson

P.S. At least one Consular officer recently said that they are expecting more renunciations because of the decrease in the renunciation fee from $2350 to $450.

P.P.S. Re Renunciation vs. relinquishment: An earlier post on Brock warned of the dangers of seeking a back-dated relinquishment as opposed to a present day renunciation. It has become far far far more difficult to get a CLN (“Certificate Of Loss Of Nationality”) based on a prior relinquishing act. You absolutely should NOT attempt a relinquishment without getting legal advice. The climate surrounding relinquishments  has definitely changed since 2011.

For those interested, here it is …

John Richardson’s Observations on Current Processing of Relinquishment-Based CLN Applications

 

The Isaac Brock Society Was Ahead Of It’s Time In Fighting For An Independent Canada

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History doesn’t repeat itself exactly. But it often rhymes!

Then and now – Issac Brock and @isaacbrocksociety.bsky.social have been supporters of a free and independent Canada.More about Sir Isaac Brock below …www.cbc.ca/news/politic…

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-04-24T18:49:03.474Z

In the  article linked above and featured in the Bluesky post above, CBC reporter John Paul Tasker writes:

 

Prime Minister Mark Carney stunned some Canadian historians over the weekend when he released a pointed video message about the U.S. featuring a War of 1812 general who led the charge against the American invaders of that era.

For the first time Sunday, Carney publicly disclosed that he takes daily inspiration from Sir Isaac Brock, a foundational figure in Canadian history who expertly prepared Upper Canada for a possible U.S. invasion and then defended the territory against the marauding American forces when they eventually marched north.

A spokesperson for Carney said comedian Mike Myers gifted him a figurine of the general during the last election — the day they filmed that now infamous “elbows up” campaign commercial — and Carney, a history buff, has since given it a prominent place on his desk at 80 Wellington St.

This is an excerpt from a really great article that is absolutely worth the read in its entirety.

Towards the end he writes:

Arthur Milnes, a political historian and an ex-speechwriter to former prime minister Stephen Harper, said so many Canadians know little of the country’s history.

While a giant in that context, Brock remains an obscure figure for many Canadians, and that’s an indictment of the school system and the curriculum that’s taught, Milnes said in an interview.

Milnes said Carney’s invocation of Brock, the Plains of Abraham and the country’s royal ties is an effort to inject the past into the present and revive a part of Canadian identity that had gone dormant before this trade war.

https://web.archive.org/web/20260424014557/https://www.cbc.ca/news/politics/sir-isaac-brock-mark-carney-9.7170975

 

In 2011 the Isaac Brock Society was founded as a blog to educate Canadians about the impact U.S tax overreach. Specifically,  United States reaching into Canada and claiming Canadian residents as U.S. tax residents. Not only was (and is) FATCA an attack on individual Canadians,  it was also an attack on Canada’s status as a sovereign country. The “realization of the attack” was often referred to by impacted individuals – as the “Oh My God” moment.

 

In 2025 Canada as a country had it’s “Oh My God” moment when it realized that when President Trump suggested that Canada should become the 51st state. The President’s threats to annex Greenland gave the threats against Canada more credibility. In 2025 and 2026 the world had its collective where it recognized the need to deleverage from and minimize dependence on the United States.

 

It was in this political and historical context that Mark Carney became the Prime Minister of Canada and has become a champion in the cause of keeping Canada independent from the United States. Note that this is NOT “Anti Americanism”. Rather, it’s a simple recognition that Canada (like other countries) must take steps to create economic independence and to diversity its interests as much as possible.

One of the founders of the Isaac Brock Society sent me the following video clip giving more information about Sir Isaac Brock.

 

— Isaac Brock Society (@isaacbrocksociety.bsky.social) 2026-04-20T22:21:27.987Z

It’s 2026. Canada must deleverage from the United States to preserve its independence and protect is sovereignty.

History doesn’t repeat itself exactly. But, it does often rhyme!

 

John Richardson

 

Heather Richardson and Vanessa Williamson – The Price of Democracy: The Revolutionary Power of Taxation in American History

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Interesting discussion about the role of tax."The Price of Democracy: The Revolutionary Power of Taxation in American History" between @heatherrichardson.bsky.social and @vanessawilliamson.bsky.socialTaxation is American and America is taxation!heathercoxrichardson.substack.com/p/american-c…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-20T01:43:12.212Z

F. Scott Fitzgerald of “The Great Gatsby” fame once wrote:

 

“Let me tell you about the very rich. They are different from you and me.”

For many years various “Americans Abroad” groups have been trying to have a rational conversation with American politicians and the general public about ending citizenship taxation. The discussions are very difficult. The difficulty is largely rooted in how Americans view taxation. I guess I could say:

“Let me tell you about how Americans view taxation. They are different from you and me.”

It has become painfully clear that America is about taxation and taxation is about America.

And speaking of the role that taxation plays and has played in American history and democracy, it’s worth listening to this fascinating conversation between Heather Cox Richardson (no relation) author of the substack “Letters From An American” and Vanessa Williamson of the Brookings Institution.

Their discussion is about Ms. Williamson’s new book: “The Price of Democracy: The Revolutionary Power of Taxation in American History“.

Incidentally, Professor Heather Richardson is leading the opposition to the Trump administration. Whether you are to the left, to the right or an independent, I recommend her Substack. She does an amazing job of putting current events in historical perspective.

John Richardson

 

 

Second Estate – How The Tax Code Made An American Aristocracy – Ray Madoff

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As goes tax policies of a nation, so goes the survival of the civilization.BC Law Prof Ray Madoff explains how and why the US tax system has created tremendous inequality and "aristocracy". Bottom line: "Salaries are for suckers"This video is worth watching!www.nytimes.com/2026/04/17/o…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-19T11:57:05.254Z

Thanks to long time Brock contributor Tim Smyth who introduced me to this fantastic article/podcast.

Ray Madoff is a Boston College law professor who is the author of a number of books including:

Second Estate – How The Tax Code Made An American Aristocracy

____________________________________________________

Why this interview is important …

Americans abroad are acutely aware of the unfairness, arbitrariness and weaponization of the U.S. tax system. There are multiple layers of unfairness. The institutional layers of unfairness include (but are not limited to):

First level 0f unfairness – defining tax residency in terms of the “circumstances of birth“ (citizenship) rather than the “circumstances of life” (where people actually live and where the activity in their lives is centered).

The unfairness includes taxation of people based on “status” (citizenship, immigration status) without regard to whether people live in the United States. The “status” based unfairness is discussed and understood only by those impacted by it.

Second level of unfairness – taxing different forms of income and assets differently

This is where this interview with Ray Madoff really shines! At the risk of oversimplification, Professor Madoff explains:

– how the tax system discriminates against people who receive their income in salary as opposed to investments; and

– how this discrimination facilitates the tremendous inequality of wealth in the United States; and

– how the tax system perpetuates and entrenches this inequality of wealth from generation to generation (hence the word “aristocracy“).

Question:

Why should income from capital gains be taxed at a lower rate than income from work?

The U.S. tax system appears to operate in a way that exempts the super wealthy from the same levels of taxation that are experienced by wage/salary earners.

I highly recommend this interview. It is the most educational hour that I have experienced in a very long time. Understanding this interview will equip you with a better vocabulary and understanding to discuss tax policy.

At one point Professor Madoff draws a direct comparison between the Canadian and U.S. tax systems. There is a brief exchange about citizenship taxation and renunciation of U.S. citizenship.

An incredibly rich discussion …

Listen to this podcast! I promise you will benefit.

John Richardson

 

The interview on YouTube:

 

 

Links to the original New York Times article:

https://www.nytimes.com/2026/04/17/opinion/ezra-klein-podcast-ray-madoff.html

https://www.nytimes.com/2026/04/17/opinion/ezra-klein-podcast-ray-madoff.html?unlocked_article_code=1.cFA.Ik6N.JNRWj6ASShrt&smid=url-share

You Know A Tax System Is Broken When Individuals Fear Tax Compliance As Much As They Fear Tax Noncompliance

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When tax compliance is weaponized because of the "status" of an individual there is a risk in attempting compliance and a risk in non-compliance. The undocumented in the USA have a lot in common with US citizens outside the USA. (NYTImes.com gift article)www.nytimes.com/2026/04/14/u…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-17T12:52:36.628Z

Part A – Why tax systems be restricted to taxation and not be used as a mechanism to enforce immigration laws

The New York Times article includes:

For decades, the I.R.S. implicitly encouraged undocumented taxpayers to file a return as part of its broader mission to promote tax compliance. Before the agreement between the I.R.S. and ICE, unauthorized immigrants paid roughly $60 billion annually in federal taxes, according to an estimate by the Institute on Taxation and Economic Policy, a progressive think tank. Much of it went to Social Security and Medicare, which are programs that undocumented immigrants cannot benefit from.

With few exceptions, taxpayer information was kept walled off from other government agencies, and that won a measure of trust among many undocumented immigrants. But under President Trump, the effort to find as many immigrants to deport as possible led the administration to try to exploit that trust.

Bottom line: The assumption that the information in a tax return would not be shared to other government agencies has been shattered. The “undocumented” have reasonable grounds for worry.

Of further interest is:

John Koskinen, who was the I.R.S. commissioner from 2013 to 2017, said the potential consequences of sharing tax data with D.H.S. were evident.

“Our job was to collect taxes owed, not enforce immigration laws,” said Mr. Koskinen. “That was the job of D.H.S. And it was clear to me that, if immigrants thought their information was going to be shared, many of them would quit filing their tax returns.”

The link in the article is a “Gift Link”. Hence, you can see the comments which are interesting.

Part B – Thinking about the FATCA related transmission of taxpayer data to the United States

Continue reading →

Naturalized U.S. Citizens – David Frum Of Canada and Fareed Zakaria Of India – Discuss Their Feelings About U.S. Citizenship

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Fascinating discussion between two well known naturalized U.S. citizens – @davidfrum.bsky.social and Fareed Zakaria – about the the meaning of U.S. citizenship and where the U.S. is today. Consensus: USA has changed and not for the better.youtu.be/hHEoPFrZIhw?…

— John Richardson (@expatriationlaw.bsky.social) 2026-04-08T21:46:20.478Z

This post is NOT for everybody. But, it is a fascinating discussion between two well known naturalized U.S. citizens about America today. It lasts about a hour. I would say it is a discussion with a 40 year perspective and a good deal of substance.

 

John Richardson