The Q2 2015 Quarterly Publication of Individuals Who Have Chosen to Expatriate has been placed on public inspection for printing in the Federal Register for 31 July 2015, one day later than required by law. This is the seventy-fifth list to appear since the passage of the Health Insurance Portability and Accountability Act, or maybe the seventy-fourth. (That depends on whether you count the 52-days-late Q3 2000 list, which was an exact duplicate of the Q2 2000 list.)
The list this quarter contains 460 names. This is the smallest quarterly total since the absurdly-small Q4 2012 list, which contained just 45 names. On the other hand, it’s also the second-fastest publication time since then too (the fastest being the Q3 2014 list, the only one to appear on time since then). During the same period covered by the newest list, the FBI’s NICS gun control database went from 28,646 renunciant records to 30,117, an increase of 1,471 renunciants — similar to the number added to NICS during the first three months of the year.
Working from the (possibly outdated, and if so probably too low rather than too high) estimate of four or five relinquishers for every six renunciants, the NICS figures suggests that at least 2,700 people gave up U.S. citizenship during those three months. On top of that, perhaps 4,500 ex-permanent residents cancelled their green cards during the same period (based on USCIS statistics from 2013).
Table of contents
- Media articles about specific relinquishments
- Comparison with NICS
- Who shows up in the expat honour roll anyway?
- Conclusion
Media articles about specific relinquishments
Here’s a table of people mentioned by name in media reports as having given up U.S. citizenship since the beginning of 2013. Only one person from the table showed up in this quarter’s list: Camillo Gonsalves, a diplomat and politician from Saint Vincent and the Grenadines who says he renounced citizenship back in September 2013. I have no idea what took State & the IRS so long to get his name printed, seeing as some people who gave up citizenship in late 2014 already showed up in last quarter’s list. On the other hand, some folks like Shere Hite took six years to get their names printed back in the early 2000s, so I guess the IRS is getting better at this after decades of practice.
| Name | Occupation | Other citizenship |
Giving up US citizenship | Appeared in Federal Register? |
Source | |
|---|---|---|---|---|---|---|
| Reason | Date | |||||
| Naftali Bennett | Politician | Israel | Members of Knesset cannot hold foreign citizenships | January 2013 | Q2 2013 | Jerusalem Post |
| Dov Lipman | Politician | Israel | Members of Knesset cannot hold foreign citizenships | January 2013 | Q2 2013 | Jerusalem Post |
| Orlan Calayag | Bureaucrat | Philippines | Become head of National Food Authority | January 2013 | Q2 2013 | Philippine Star |
| Mahmud Karzai | Politician | Afghanistan | Launch political career in Afghanistan | January 2013 | Q1 2013 | Radio Free Europe |
| Bernard Chan Pak-li | Scientist, bureaucrat | Hong Kong | Join Commerce & Economic Development Bureau | February 2013 | Q2 2013 | HK Economic Times |
| Fauzia Kasuri | Politician | Pakistan | Pakistan does not allow politicians to hold dual citizenship | March 2013 | No | Dawn (Pakistan) |
| Marshall Nicholson | Investment banker | Hong Kong | Unclear — probably career-related (he worked in a Chinese-owned fund) | April 2013 | Q4 2013 | Reuters |
| René González | Intelligence | Cuba | Part of deal with DOJ to end parole & return to Cuba | May 2013 | No | Washington Post |
| Quincy Davis | Basketball player | Taiwan | Naturalise & join national basketball team | June 2013 | Q4 2013 | China Post |
| Glen L. Roberts | Writer | None | To become stateless | June 2013 | Q4 2014 | Int’l Business Times |
| Camillo Gonsalves | Diplomat, politician | St. Vincent & Grenadines | Join Senate of SVG | September 2013 | Q2 2015 | I-Witness News (SVG) |
| Michael Putman | Librarian, translator, editor | Canada | “[F]ully assimilate into the civic and cultural life of my new country” | September 2013 | No | BBC |
| Tina Turner | Singer | Switzerland | Unclear | October 2013 | Q1 2014 | Forbes |
| Lu Shu-hao | Military | Taiwan | Service in Republic of China Army | January 2014 or earlier | No | Taipei Times |
| Sandy Opravil | Housewife | Switzerland | Save her mortgage | February 2014 | Q3 2014 | Newsweek |
| Roger Ver | Bitcoin investor | St. Kitts & Nevis | Libertarian political opinions | February 2014 | No | Bloomberg |
| Sophia Martelly | Politician | Haiti | Run for Senate of Haiti | March 2014 | No | Haiti Press Network |
| Ya’aqov Ben-Yehudah | Writer | Israel | Complicated; see source | March 2014 | Q2 2014 | Times of Israel |
| Sean Cavanaugh | Technology | Canada | FATCA | April 2014 | Q1 2015 | Tweeted own CLN in August 2014 |
| Mona Quartey | Politician | Ghana | Become Deputy Finance Minister of Ghana | July 2014 | No | Graphic News (Ghana) |
| Alex Kim | Pop star | South Korea | Obtain South Korean citizenship & serve in military | August 2014 | No | Herald Business (South Korea) |
| Nicole Beaudoin | Unknown | Canada | FATCA | September 2014 | Q3 2014 | La Presse (Canada) |
| Kim Sungkyum | Military | South Korea | Be commissioned an officer in the Republic of Korea Army | December 2014 | Q1 2015 | Kookbang Ilbo (South Korea) |
| Lin Jou-min | Architect | Taiwan | Take position in Taipei city government | December 2014 | No | Central News Agency (Taiwan) |
| Rachel Azaria | Politician | Israel | Members of Knesset cannot hold foreign citizenships | January 2015 | No | Times of Israel |
| Jonathan Tepper | Macroeconomic analyst | United Kingdom | FATCA & other U.S. tax reporting requirements | January 2015 | No | The New York Times |
| David Alward | Politician | Canada | To become Canadian consul-general in Boston | April 2015 or earlier | No | Canadian Broadcasting Corporation |
Comparison with NICS
On 31 December 2014, NICS had 27,240 renunciant records, according to the FBI’s 2014 NICS operations report. The below table lists the monthly additions to NICS since then, compared with the quarterly lists in the Federal Register. The FBI has the bad habit of uploading the new NICS report each month at the same URL as the old one; the only way to keep a verifiable collection of old reports is to save old ones in the Internet Archive each month, and unfortunately we didn’t remember to do this for all months. As a result, the January and February links go to Innocente’s comments, rather than copies of the FBI’s PDF files.
| NICS | Federal Register | |||
|---|---|---|---|---|
| Month | Month-end total | Increase | Quarter | Count |
| January 2015 | 27,511 | 271 | Q1 2015 | 1,336 |
| February 2015 | 27,616 | 105 | NICS Q1 Total | 1,406 |
| March 2015 | 28,646 | 1,030 | Est. non-NICS relinquishers | ~1,200 |
| April 2015 | 29,413 | 767 | Q2 2015 | 460 |
| May 2015 | 29,956 | 543 | NICS Q2 total | 1,471 |
| June 2015 | 30,117 | 161 | Est. non-NICS relinquishers | ~1,200 |
Who shows up in the expat honour roll anyway?
There’s two major disputes over the contents of the Federal Register lists: is it required (and does it bother) to include (1) former long-term permanent residents, and (2) non-covered expatriates? Both of these disputes revolve around some horribly-ambiguous wording in the last sentence of 26 USC § 6039G(d):
Notwithstanding any other provision of law, not later than 30 days after the close of each calendar quarter, the Secretary shall publish in the Federal Register the name of each individual losing United States citizenship (within the meaning of section 877(a) or 877A) with respect to whom the Secretary receives information under the preceding sentence during such quarter.
877(a) doesn’t define what it means to lose United States citizenship at all; it only defines what it means to be subject to the tax in 877(a). However, 877A(g)(4) does define what it means to “relinquish citizenship”.
Former long-term permanent residents?
Beginning from the Q1 2012 list, the IRS began to claim that “For purposes of this listing, long-term residents, as defined in section 877(e)(2), are treated as if they were citizens of the United States who lost citizenship.” However, those who believe this claim, or who repeat it without fact-checking it (e.g. most of the media), have never provided the name of single person who was verifiably a non-citizen long-term permanent resident and who appeared in the Federal Register.
The one country in which it is easiest to find media reports of named people giving up U.S. green cards is South Korea, because of the legal requirement there (soon to be abolished) for people who obtain foreign permanent residence to cancel their South Korean resident registration, and for them to prove cancellation of their foreign permanent residence to regain that domestic resident registration. None of the people named in those reports showed up in the Federal Register list (and all of them were pop stars, suggesting they had sufficient assets to meet the “covered expatriate” threshold, in the event that’s relevant at all to the list).
The question of whether the list is supposed to include ex-LPRs is a bit more challenging. Even after the most recent revision to Form I-407 in February 2015, USCIS still doesn’t collect Social Security numbers or length of time since the person obtained the green card from the 1,500 or so people who cancel their green cards each month. This means that the data they provide to the IRS on green card cancellations probably remains as useless as it was back in 2000.
Furthermore, Virginia La Torre Jeker, in comments at AngloINFO, disagrees that 6039G(d) even gives the IRS the authority to print the names of green card holders in the first place:
Frankly, the law in Sec 6039G states per below that the name of each individual “losing United States citizenship (within the meaning of section 877 (a) or 877A)” should be published in the Federal Register. First, it is not clear to me that United States citizenship is the same as holding a green card! Second if one refers to the referenced Code sections of Section 877(a) and 877A – these refer to those persons who are deemed to have a tax avoidance motive / fail to make the tax certification and either lose US citizenship or long term lawful permanent resident status (i.e., after having such status for 8 tax years out of the preceding 15 tax years). As such, certainly not all green card holders should be listed in the Fed Reg. and further, I wonder if ANY should be listed at all given the wording in 6039G, to wit — “losing United States citizenship”.
877A definitely does not include abandonment of a green card under the definition of “relinquishment of citizenship”; it only includes it under “expatriation”, and since, as Ms. La Torre Jeker mentions, the statute only permits publication of the names of people “losing United States citizenship”, it’s doubtful the IRS has the authority to print the names of ex-green card holders. So if you do happen to know the name of an ex-green card holder appearing in the Federal Register, it could indicate that Treasury Secretary Jack Lew is in violation of 26 USC § 6103. Try dobbing him on Form 211 for your whistleblower reward!
Uncovered expatriates
David Lesperance and several others have suggested that the list only contains covered expatriates.
From Bill Yates’ earlier interview with Virginia La Torre Jeker (discussed by Brockers here), we know that in the early 2000s the U.S. government was thinking of trying to enforce the Reed Amendment by comparing names of arriving travellers to the expat honour roll and making them waive their Section 6103 privacy rights so the IRS could release their records to the Justice Department and the Attorney General could determine whether or not the person “renounced United States citizenship for the purpose of avoiding taxation by the United States”.
Similarly, William J. Krouse of the Congressional Research Service wrote back in 2000, in the context of Reed Amendment enforcement:
As required by HIPA, IRS publishes a list quarterly in the Federal Register of the names of persons who have renounced their U.S. citizenship (expatriates) and who, by having renounced citizenship, may have done so to avoid taxation and may meet tax liability or net worth tests under 877(a). The IRS, however, does not make a preliminary determination based upon its records whether these expatriates meet either test and, thus, would be inadmissible into the United States. Consequently, these lists include expatriates whose motivation may not have been tax avoidance, and whose exclusion might be an embarassment to the United States.
Both Yates’ and Krouse’s statements seem to imply that non-covered expatriates are supposed to be in the list. This would also square with the previous observation that almost all ex-citizens of 2006-or-earlier vintage showed up in the Federal Register — even South Korean apple farmers supporting a family of five on US$25,000/year.
Obviously, the biggest relevant legislative change since Krouse wrote that quoted passage was the American Jobs Creation Act of 2004. Before it passed, there was a definite procedure for deciding that an expatriation had avoidance of taxation as “one of its principal purposes”: people who met the “covered expatriate” test of 877(a)(2), and who didn’t fall under any of the statutory exceptions, could apply for private letter rulings about the “principal purposes” of their expatriations. Afterwards, however, Congress took away the IRS’ authority to make judgment calls, and there would be no more investigations of the “purposes” of an expatriation; if you met the asset, tax liability, or missing tax forms test, you were subject to the expatriation tax.
However, if Mr. Krouse accurately described the IRS’ procedures for compiling the Federal Register list, I don’t see why the AJCA would have spurred the IRS to change those procedures. Besides, if the IRS were trying to restrict the list to covered expatriates, they would have to wait until each expatriate’s tax return due date — as late as October in the year following the loss of citizenship or green card — before publishing the name. Without a Form 8854 in hand, the IRS usually has no way of knowing whether a person is a covered expatriate (unless & until they become one by passing their tax return date without having filed that form), but as the table above demonstrates, some lucky people appear in the expat honour roll during the same year in which they relinquish citizenship.
There might be one case in which a person who has not yet filed a Form 8854 could already be known to the IRS to be a covered expatriate: if the IRS receives the person’s CLN, the person did not file U.S. taxes in the past five years prior to the expatriation date, and the IRS has proof that the person had sufficient income to generate a filing requirement. The third condition in particular should have been rather rare up until now, unless the person had U.S.-source income; FATCA might change this situation, though.
Other theories
Some folks think that non-renunciant relinquishers do not appear in the Federal Register. We’ve discussed this idea in the comments section here a few times, and John Gaver once advanced this theory on his blog and specifically predicted that Tina Turner would not appear. According to the Washington Post, Turner confirmed to the U.S. consulate that her acquisition of Swiss citizenship was performed with intent to relinquish U.S. citizenship under 8 USC § 1481(a)(1). Turner’s name showed up in the Q1 2014 list. The Post also claimed that relinquishers don’t pay the exit tax, and had to issue a correction a few days later, so maybe they’re wrong about everything else they said too; however, other people whose publicly-posted CLNs show that they relinquished instead of renouncing (e.g. Petros) have also appeared in the list.
Robert Wood wrote last year that the list does not include “[w]hat is often called consular expatriations, where people don’t file exit tax forms with the IRS”. I’m not quite sure what “consular expatriations” are; these days, all expatriations involve showing up at a consulate in person, unlike the good old days when you could get rid of your unwanted citizenship by mail (something which you can still do in civilised countries like Ireland — and without paying an absurd fee, either).
Conclusion
The list has some names in it. They belong to people whose names the IRS decided to publish. There are other people whose names the IRS accidentally forgot to publish, or deliberately decided not to publish, or whatever. Ex-green card holders probably aren’t in the list. Everything else is a toss-up. Even lawyers can’t figure it out. Caveat lector.
In term of the numbers cited re UBS, I question how many of the accounts were of US homeland residents vs. Swiss nationals working/studying/living in the US who had pre-existing accounts.
I remember being surprised at the scope of Swiss-US investment, business, trade and the numbers of Swiss workers sent to the US for Swiss corporations/businesses. I dug up an earlier post with some of that info:
https://isaacbrocksociety.ca/2012/01/12/u-s-citizenship-based-taxation-harms-u-s-economy/comment-page-2/#comment-63025
“http://www.eda.admin.ch/eda/en/home/reps/nameri/vusa/wasemb/waecon/wasuss.html
US – Swiss Economic Relations
Foreign Direct Investments and Jobs
“With foreign direct investment in the U.S. amounting to
over USD 189 billion in 2009, Switzerland ranks among the top six
foreign direct investors in the United States. A large number of Swiss companies have considerable operations in the United States. U.S. subsidiaries and branches of Swiss companies provide jobs for over 500,000 people throughout the United States.
With direct investment from the United States to Switzerland exceeding USD 148 billion, Switzerland is the seventh most important destination for U.S. foreign direct investment. Over 620 U.S. companies have an establishment in Switzerland.
Trade in Goods and Services
Switzerland is an important customer for U.S. products. Exports of goods from the United States to Switzerland were valued at USD 7.4 billion in 2009 (cif). In the same period, Switzerland’s exports of goods to the U.S. amounted to USD 16.27 billion (fob).
With
respect to the exchange of services, the exports from the United States
to Switzerland in 2008 exceeded USD 18 billion, whereas the imports
reached USD 17.54 billion. “
Sources: U.S. Department of Commerce, Bureau of Economic Analysis and Swiss-American Chamber of Commerce
”
and everyone should re/read this:
‘No one in Youngstown, Ohio has a Swiss bank account’…Except for Maybe That Big New Swiss Employer in Town?’
Matt Welch Jul. 16, 2012 9:36 am
http://reason.com/blog/2012/07/16/no-one-in-youngstown-ohio-has-a-swiss-ba
excerpt;
“….Really? No one in Youngstown has a Swiss bank account? That might come as news to executives at this new local job-creator:
YOUNGSTOWN – Another major player in the oil and gas industry has decided to set up shop in the Mahoning Valley, bringing about 150 jobs with it.
Geneva, Switzerland-based Weatherford International Ltd. plans to put a “multipurpose operations facility” into a building it bought April 20 at 1110 Performance Place in Youngstown’s Salt Springs Industrial Park.
The company said it will employ about 150 at the facility, which tentatively is scheduled to start operating in late September.
Remember: Because of the populist, economically illiterate Foreign Account Tax Compliance Act, Swiss citizens working in the United States at American-job-creators like Weatherford are being unceremoniously dumped by their banks back home. Imagine for a moment going to your ATM to pull out money, and seeing the message “account closed.” I have talked to multiple Swiss expatriates and bankers alike who say that that’s now commonplace.
Why should we care about a bunch of goddamned fondue-eating Novartis executives? Switzerland was by several accounts the largest source of foreign direct investment into the United States in 2010 [PDF], and is consistently among the top foreign investors in the presumably Ohio-friendly field of manufacturing. The Swiss government estimates that Swiss companies employ a half-million Americans.
So we are now actively infuriating not only some of the roughly five million American expatriates who are seeing their bank accounts shuttered all over the globe, but also the very type of job-creating Swiss investors and executives to whom a prudent country might be a tad more welcoming. As this Congressional Research Service report [PDF] puts it, “Foreign direct investments are highly sought after by many state and local governments that are struggling to create additional jobs in their localities.” Do tell.
Like the January statement from Sen. Carl Levin (D-Mich.) that “There is no such thing as an ordinary Swiss bank account,” Tim Ryan’s claim that “No one in Youngstown, Ohio has a Swiss bank account” is becoming a self-fulfilling prophecy, precisely because of consequence-oblivious millionaire Democratic politicians like Carl Levin and Barack Obama. And it’s cities like Youngstown that stand to suffer most…”….
To illustrate badger’s point that many of the Swiss “cross-border” bank accounts held by US residents may actually be just Swiss living in the US, I reviewed the the Non-Prosecution Agreement (NPA) between the DOJ and Bank Linth, a regional retail bank in eastern Switzerland. Some of the remarks in the NPA would seem to support this contention:
“Bank Linth focuses primarily on local and regional clientele, therefore, all of its forms, publications and marketing advertisements are in German. Bank Linth’s website is also in German.”
“…Bank Linth provided private banking and asset management services to individuals and entities outside of Switzerland, including citizens and residents of the United Statess (“U.S. taxpayers”). The majority of Bank Linth’s U.S: clients are Swiss residents, who in most cases have Swiss and U.S. passports.”
“…Bank Linth’s relationship managers are not required to speak English and do not take business trips to the U.S.”
“In the Applicable Period, the Bank held a total of 126 U.S. Related Accounts with just over $102 million in assets. … Approximately 59 of the 126 accountholders were U.S. citizens. Of those, 31 held joint U.S. and Swiss citizenship, and approximately 34 were domiciled in Switzerland. Approximately 67 of the 126 accountholders were domiciled in the United States; four had domiciles in both Switzerland and the United States.”
Note that 67 (126-59) of the account holders were not U.S. citizens, which is also the number of account holders domiciled in the US. This may suggest that these are Swiss living in the U.S.
@Innocente, classic case of mafia/organized crime shake down tactics.
I also went through the numbers…….
At the end of the filter, twenty five persons (25) who were either dual US/CH or sole US were living in the USA.
No wonder FFI want to dump anyone and everybody with any US taint. To be honest, if I was hired in a compliance department I would be a big sign out front that said Yankees Go Home.
My name was on this quarter’s list and, with all deference to legal expert David Lesperance (a former neighbor!), I was not/am not a “Covered Expat”. My name appeared 15 months after renunciation. Hubby renounced a year and a half before me yet his name still has not arrived on the Name And Shame List (and he was not/is not a Covered Expat” either). Both our adult children renounced and were on the list within about 12 months; they certainly would not qualify as “Covered”. So that hypothesis is tossed aside.
My own hypothesis is that the IRS is overworked and not terribly organized about this legal obligation, adding names in bunches now and then and trying to keep the numbers as low as practical to not scare the homelanders too much.
Will we ever know? There are way too many of us who appear who should not be deemed *Covered Expatriates*.
Wikipedia weighs in:
(Perhaps those *most knowledgeable* about the US Constitution and US tax requirements, those Canadian Government lawyers we’ll be meeting on August 4th, can instruct us???!!)
It’s so ridiculous that everyone has to play guessing games to try to figure out who is on the list, who is supposed to be on the list, and if a renounced/relinquished person’s name was not on the list — why not? Just ridiculous.
Wikipedia is about as trustworthy as the last person to edit it. A few months ago, someone whose name you may recognize rewrote that Wikipedia article to claim that only covered expats showed up in the list
https://en.wikipedia.org/w/index.php?title=Quarterly_Publication_of_Individuals_Who_Have_Chosen_to_Expatriate&type=revision&diff=662365150&oldid=661475538
Then I rewrote it to roughly its present form.
https://en.wikipedia.org/w/index.php?title=Quarterly_Publication_of_Individuals_Who_Have_Chosen_to_Expatriate&diff=next&oldid=662415947
@Eric — Thank you for this. And thank you for all the amazingly brilliant analyses you post here!
@ Eric
Remember this?
http://www.examiner.com/article/obama-drives-record-10-000-wealthy-u-s-taxpayers-to-renounce-citizenship
Anyway thank you for correcting the Wikipedia entry. I don’t know why JG is so stuck on his theory that only the covered are listed but he is.
And I echo Canoe’s thank you. Nobody slices and dices the federal register as well as you do.
Here’s a name to watch for on the final ‘name and shame’ list – for later in this year. Another political figure (a mayor in Ghana) is said to have renounced his US citizenship as of August 31st, 2015;
“Mayor of the Accra City, Alfred Oko Vanderpuije has announced that he dropped his US citizenship effective Monday, August 31.
Speaking on Accra based Starr FM, Mr. Vanderpuije said the decision to renounce his American citizenship is because he wants to stand for political power. He has shown interest of contesting the Ablekuma South parliamentary primaries on the ticket of the governing National Democratic Congress.
The Accra Mayor hitherto held a dual citizenship for 30 years.”
from http://yen.com.gh/19705-accra-mayor-renounces-us-citizenship.html
and see also;
http://m.starrfmonline.com/1.6497297
And will the US fleece him too, like they reportedly did to London’s Mayor Boris Johnson?
Sorry, I guess the Aug. 31 renunciation I refer to above would appear in the 3rd quarter name and shame list, not the last quarter.
Federal Register Expatriation list for 3Q 2015 is available listing approximately 1,429 names of former USCs. Congratulations to them!
https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-27281.pdf
Well folks, I made the list this time. Congrats to my fellow renouncers/relinquishers. Looks like we all have lots of company this quarter. Thanks Innocente.
Nice. I guess at this point (3+ years after renunciation) it’s pointless for me to keep checking if my name has been included, however.
Andrew Mitchel’s “International Tax Blog” is on top of this today and published the following:
“2015 Third Quarter Published Expatriates – A Record High
Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2015.
The number of published expatriates for the quarter was 1,426. This is the highest quarterly number of published expatriates ever, surpassing the previous record of 1,335 that was set earlier this year (Q1 2015). The number of published expatriates for the first three quarters of 2015 has been 3,221 (1,335 + 460 + 1,426).
Last year, there was a record-setting 3,415 published expatriates. Only an additional 195 published expatriates in the fourth quarter would be required for a new record to be set. If a new record is set, this would be the third consecutive year with a year over year increase. For a discussion of how the IRS compiles the data, see this post.
We continue to believe that the IRS is likely missing a significant number of names from its quarterly publication of expatriates. During the third quarter of 2015, the FBI has added 1,558 individuals who renounced their U.S. citizenship to the NICS index.”
http://www.intltax.typepad.com/
A comparison of IRS figures to FBI NICS for the first nine months of 2015:
IRS: 3,221 USC renunciations, USC relinquishments, long-term green card abandonments
FBI NICS: 4,435 USC renunciations (only)
Eric listed 12 names of individuals in his commentary above who stated publicly that they had renounced but whose names had not appeared on the IRS lists through 2Q 2015. Four of these names are now on the 3Q 2015 list:
Michael Putnam
Sophia Martelly
Lin Jou Min
David Alward
Wow, that’s early for the list to be released! Record-breaking, actually (at least within my memory). I guess the increase in renunciation fees is resulting in greater efficiencies. Something the State and Treasury Departments should get gold stars for.
Well, it looks like they are about a year behind in reporting. I renounced in August 2014, back filed 5 and a half years plus 8854 this past June, and am just now on the list.
That’s the way it’s been played out for some years now, unleashed. Congratulations on making it onto the *Name and Shame List*, along with others – mine from 2012 took a couple years to make it.
The above posted article from International Tax Blog Innocente’s provided contains a link to another that covers just who’s on the name and shame list and how they got there:
Summary
The list in the Federal Register is required to include all U.S. citizens losing their U.S. citizenship and all long-term permanent residents terminating their U.S. lawful permanent resident status. The list does not only include individuals that are subject to the exit tax (for example, by meeting the net worth test or the tax liability test). The I.R.S. obtains the information to determine which names should be included on the list from three different sources: I.R.S. Forms 8854, Secretary of State CLNs, and from USCIS.
http://intltax.typepad.com/intltax_blog/2014/02/quarterly-list-of-expatriates-source-of-data.html
Another record breaking quarter and the cynic/realist in me thinks:
1) No one in the US cares about the ex-pat plight. List shows whole families forced to renounce and Joe Six-Pack could care less.
2) The fact that the IRS is tasked with publishing the list, and not the State Department speaks volumes. This is all about taxation– namely Citizenship Based Taxation. US ex-pats are being cheated out of their birth right. United States of Eritrea.
Still not on the list here.
“2) The fact that the IRS is tasked with publishing the list, and not the State Department speaks volumes. This is all about taxation– namely Citizenship Based Taxation.”
No, it’s 1% about ET (Eritrean style extraterritorial Taxation) and 99% about Penalties. The 99% don’t owe any US tax.
“Name and Shame List”
Please spell Honour Roll correctly.
Wow, the list is on time and there don’t seem to be any duplicate names in it! They must be putting the fee increase for renunciations/relinquishments to “good” use in improving their system. But it’s still just a list of names and still incomplete. It remains a bizarre artifact of U.S. government law and bureaucracy. Whatever money is spent on producing and publishing it could clearly be put to better use.