The FBI has released its latest report on Active Records in the NICS Index, updated to 31 March 2013. NICS now contains the records of 21,504 persons who are prohibited from purchasing firearms in the United States because they swore an Oath of Renunciation of United States Citizenship at a U.S. consulate abroad. This is an increase of 196 records as compared to 28 February, and 850 records in the first quarter of 2013 (since 31 December 2012). The quarterly number of renunciants shows an increase of 88% as compared to the same period last year — as we reported two months ago, 452 records of renunciants were added to NICS in the first three months of 2012.
However, the number of renunciants has declined since the third and fourth quarters of 2012, which showed an average of 1,744 people renouncing (a breakdown for each quarter is not available because the FBI did not issue a NICS report for the month of September, meaning the October figure listed in the table represents an increase for two months, straddling the boundary of the third and fourth quarters).
Assuming that the number of renunciants reported by the FBI is accurate, the next question to ask in analysing this data is whether we expect that the number of renunciants should show a seasonal trend or not; that is to say, should we be comparing to the same quarter in the previous year, or the previous quarter. This is hard to tell from the existing data — we only have monthly NICS renunciation data going back for less than two years, and while we have more than a decade-and-a-half of IRS “published expatriate” data, analysing it for seasonal trends is difficult because the delay in the publication of names is large and not-well-understood — some people show up in the Federal Register within a couple of months, while others take more than a year, and the delay itself may change from year to year.
Some drivers of renunciation are distributed essentially randomly throughout the year — election candidacy dates for public offices or admissions dates to military officer training schools in roughly 200 countries and territories on the planet. But one big driver has a very obvious seasonal component: if you want to avoid being subject to onerous U.S. financial reporting requirements for yet another 1040 & FBAR filing season, you have to commit an “expatriating act” before 31 December. And of course, as those reporting requirements become more onerous, we wouldn’t expect to see a decrease in the number of people renouncing citizenship going forwards. (Incidentally, if the trend is seasonal and the number of renunciants for each of the coming quarters is also 88% higher than the same period in the previous year, that — along with the five or six-to-four ratio of renunciants to relinquishers — would suggest that about fifteen thousand people will give up U.S. citizenship this year.)
But all of this is just speculation and back-of-the-envelope calculations. When it comes to a set of suspicious and hard-to-understand numbers, it’s always better to have more eyes and more minds than fewer, but mainstream media attention to this story has been almost entirely absent. Major newspapers and the lawyers they quote continue to show no awareness of the FBI’s NICS data, and so they theorise based solely on the IRS data that “most of the individuals who have decided that their U.S. citizenship is not worth the cost of continuing to file U.S. tax returns have already renounced their citizenship”. So far, only Advisor.ca — published by Rogers Media of Canada — has written a story about the discrepancy between the FBI and IRS data on loss of citizenship.
Anyway, it will be quite interesting to see how many of these renunciations the Federal Register will admit to when Ann Gaudelli over at the IRS gets around to publishing it next month or later.
Hummmm
Advisor.ca didn’t spend much time trying to understand the difference between FBI 3000 and IRS 45 when they makes statements like this below. They talk as if the FBI numbers are less than the IRS numbers, and that obviously is not the case. So they apparently do not understand what they are writing about.
H.R. 597 This legislation would establish a commission to study how federal laws and policies affect U.S. citizens living in foreign countries .
from your congressman :
Dear Mr. XXXXXXXXXX
Knowing of your interest in the Commission on Americans Living Abroad Act (H.R. 597 ), I would like to take the opportunity to update you on this legislation.
As you know, H.R. 597 was introduced by Congressman Carolyn Maloney ( NY -1 2 ) on February 8 , 201 3 . This legislation would establish a commission to study how federal laws and policies affect U.S. citizens living in foreign countries . You may be interested to know that H.R. 597 has been referred to the House Oversight and Government Reform Committee, House Financial Services Committee, House Ways and Means Committee, House Judiciary Committee, House Administration Committee, House Energy and Commerce Committee, House Education and the Workforce Committee , where it awaits further review.
As a member of the Financial Services Committee , I look forward to a thoughtful and thorough discussion of this legislation. Please be assured that I will keep your thoughts in mind as this issue comes before the committee for consideration and as the bill works its way through the legislative process.
Thank you for contacting me. As Congress debates solutions to the challenges facing our nation, I hope you will continue to share your thoughts and views with me. Should you have any further questions or comments about this or any legislative issue, please do not hesitate to contact me in my Washington, D.C. office at (202) 225-4465. Also, please visit me at http://www.facebook.com/repscottgarrett , http://www.youtube.com/repscottgarrett , and my website at http://www.house.gov/garrett to sign up for my e-newsletter for the latest updates from Washington, D.C. and around the district.
Sincerely,
Signature
Scott Garrett
Member of Congress
@Eric
Just to mention that your postings on the inconsistency of reported US citizenship expatriations is appreciated. You’ve broken new ground several times in this area. Thanks again.
I’ll second that thanks to Eric, Innocente. The facts Eric has highlighted at Isaac Brock are indeed ammunition in telling the factual story of number of US expatriations.
FBI NICS report at 30 Apr 2013 is now available. 1’169 are recorded in the FBI records as having renounced in the period Jan-Apr 2013, which is a 78% increase over the same four-month period for 2012, when 656:
http://www.fbi.gov/about-us/cjis/nics/reports/active-records-in-the-nics-index-033113.pdf
Using Eric’s factor range of relinquishments to renunciations, this suggests that 1’948 to 2’104 US citizens expatriated in the first four months of 2013.