The Quarterly Publication of Individuals, Who Have Chosen to Expatriate for Q4 2016 has been placed on public inspection for printing in tomorrow’s Federal Register, ten days later than required by law. The IRS gave 2,365 names in this list, making it the largest they’ve ever published. We had a total of 5,411 published expatriates in 2016 (1,158 in Q1, 509 in Q2, and 1,379 in Q3). That’s slightly larger than the 5,321 federal additions to the “Renounced U.S. Citizenship” category in the FBI’s NICS gun control database last year. However, NICS only includes 8 USC § 1481(a)(5) renunciants, whereas the Federal Register is supposed to include relinquishers under other paragraphs of 1481(a) as well.
How many non-renunciant relinquishers are there? We’re not sure. In January, the State Department published updated Paperwork Reduction Act estimates stating that about 600 people per year file Form DS-4079, “Request for Determination of Possible Loss of United States Citizenship”. After the Foreign Affairs Manual update two years ago, DS-4079 is no longer used for renunciation cases, so that gives a lower bound on the number of 1481(1) to (4) relinquishers. The tens of thousands of people who abandon green cards each year definitely aren’t in the IRS list either, even though it misleadingly claims that “[f]or 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”.
The list is not only incomplete, but slow to include names; for example, Rachel Heller, who renounced all the way back in November 2015, didn’t show up until this quarter. Brockers who gave up citizenship as recently as August of last year did get their names published, but Japanese politician Kimi Onoda, who renounced in October 2016, is not included in the current list. In other words, we are not yet seeing the impact of the U.S. election results. The sudden growth in the list has some other cause.
Table of contents
- Who are the people in this list?
- And when did they give up citizenship?
- Comparison with NICS
- Table of recent relinquishments by public figures
- Media articles about the list as a whole
Who are the people in this list?
I’m sure the media coverage of this list will continue to be largely misleading. So it’s worth repeating what I said last quarter: the people in this list are not “fleeing the country”. They left years or even decades ago. (Some didn’t even know for most of their lives that they were U.S. citizens.) Their appearance in this list means that, after having settled in another country for many years, they have taken the step of obtaining a Certificate of Loss of Nationality from the U.S. government.
Some were self-identifying Americans abroad who saw cutting off their legal ties to Washington, DC (and its coterie of self-serving revolving-door bureaucrats who pretend they don’t know that they’re ruining our lives) as the only way to survive all the damage that previous presidents and Congresses inflicted on the diaspora. They’d reached their breaking points long before anyone knew who’d even be on the ballot in November, let alone how long it would take the next administration to follow through on its promises to make things right.
Others considered themselves primarily as citizens of other countries, and saw U.S. citizenship as a barrier to their lives in the country they considered home. They didn’t have any stake in who’d be U.S. president — but instead of making it easy for these de facto non-Americans to become de jure non-Americans, the U.S. government put all sorts of unnecessary barriers in their way, turning what should have been an amicable split into a bureaucratic nightmare.
And when did they give up citizenship?
In theory, if the State Department were reasonably prompt in forwarding Certificates of Loss of Nationality to the IRS, this list would contain the names of people who relinquished U.S. citizenship in October, November, or December of 2016. In practice, though a small number of people do show up in the list directly after the calendar quarter when they renounce, most people take at least six months to a year.
I expect that the bulk of the people named in this latest list made their final visit to a U.S. consulate well before the Homeland election night. Furthermore, it takes months just to get that final appointment (unless you have the cash & time to take an overseas renunciation vacation to Iceland or Mexico), meaning that the latest batch of published expatriates probably started their bureaucratic odyssey back in early-to-mid 2017 or even 2016.
So I seriously doubt that this list reflects any effect from the U.S. election results yet. (On the margins, a few people might have decided to cancel or delay their consular appointment at the last minute in order to wait and see if the Republicans would fulfill their big campaign promises. However, that would make the list smaller rather than bigger.) Anyway, whatever influence the election might have on people’s decisions about their U.S. citizenship, the results probably won’t start showing up until next quarter’s list at the earliest.
Comparison with NICS
The below table lists the monthly additions to NICS for 2011–2016, compared with the quarterly lists in the Federal Register. As you’ll notice, this is the first year since 2011 that the Federal Register actually listed more ex-citizens than NICS did.
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, though we’ve had a good track record over the past year. If the month is set in upright type, the link goes to an actual Internet Archive copy of the FBI NICS report for that month. If the month is in bold type (for December), the link goes to the NICS annual operations report for the appropriate year. Finally, for months in italics, the link goes to a Brock post or comment.
Update, 9 February, 08:45 GMT: I added years 2006–2010 to the table. The earliest NICS monthly report I’ve been able to dig out of the Internet Archive is for February 2010, and I couldn’t find enough 2010 reports to give a decent picture of the monthly updates. So for years before 2011, the table only lists an annual NICS total, based on the difference between that year’s annual report and the previous one. The State Department, which provides the FBI with CLNs of renunciants to populate the “Renounced U.S. Citizenship” category, sent one large batch of CLNs in 1998 when NICS was created, but appear not to have sent any more until 2006; for example, the 2000 and 2005 annual reports both showed 12,603 “Renounced U.S. Citizenship” records.
|First quarter||Second quarter||Third quarter||Fourth quarter|
|71 FR 25648||100||71 FR 50993||31||71 FR 63857||41||72 FR 5103||106|
|Annual totals for 2006||Fed. Reg.||278||NICS||48||12,651|
|72 FR 26687||107||72 FR 44228||114||72 FR 63237||105||73 FR 7631||144|
|Annual totals for 2007||Fed. Reg.||470||NICS||317||12,968|
|73 FR 26190||123||73 FR 43285||23||73 FR 65036||22||74 FR 6219||63|
|Annual totals for 2008||Fed. Reg.||231||NICS||655||13,623|
|74 FR 20105||67||74 FR 35199||15||74 FR 60039||158||75 FR 9028||503|
|Annual totals for 2009||Fed. Reg.||743||NICS||714||14,337|
|75 FR 28853||179||75 FR 69160||560||75 FR 69158||397||76 FR 7907||398|
|Annual totals for 2010||Fed. Reg.||1,534||NICS||1,009||15,346|
|First quarter||Second quarter||Third quarter||Fourth quarter|
|Apr 2011||41||15,387||Jul 2011||89||15,705||Oct 2011||118||15,930|
|May 2011||98||15,445||Aug 2011||54||15,759||Nov 2011||40||15,970|
|Jun 2011||131||15,616||Sep 2011||53||15,812||Dec 2011||34||16,004|
|Q2 total||270||Q3 total||196||Q4 total||192|
|76 FR 27175||499||76 FR 46898||519||76 FR 66361||403||77 FR 5308||360|
|Annual totals for 2011||Fed. Reg.||1,781||NICS||656||16,004|
|Jan 2012||265||16,269||Apr 2012||204||16,662||Jul 2012||22||17,188||Oct 2012||3,106||20,577|
|Feb 2012||98||16,367||May 2012||Missing||Aug 2012||149||17,337||Nov 2012||97||20,654|
|Mar 2012||89||16,458||Jun 2012||504||17,166||Sep 2012||114||17,451||Dec 2012||0||20,654|
|Q1 total||452||Q2 total||708||Q3 total||285||Q4 total||3,203|
|77 FR 25538||460||77 FR 44310||189||77 FR 66084||238||78 FR 10692||45|
|Annual totals for 2012||Fed. Reg.||932||NICS||*4,648||W/o backlog:
|Jan 2013||176||20,830||Apr 2013||319||21,823||Jul 2013||298||22,908||Oct 2013||302||23,557|
|Feb 2013||478||21,308||May 2013||374||22,197||Aug 2013||278||23,186||Nov 2013||118||23,675|
|Mar 2013||196||21,504||Jun 2013||413||22,610||Sep 2013||69||23,255||Dec 2013||132||23,807|
|Q1 total||850||Q2 total||1,106||Q3 total||645||Q4 total||552|
|78 FR 26867||679||78 FR 48773||1,130||78 FR 68151||560||79 FR 7504||631|
|Annual totals for 2013||Fed. Reg.||3,000||NICS||3,153||23,807|
|Jan 2014||320||24,127||Apr 2014||382||24,602||Jul 2014||577||26,000||Oct 2014||426||26,916|
|Feb 2014||95||24,222||May 2014||205||24,807||Aug 2014||180||26,180||Nov 2014||187||27,103|
|Mar 2014||-2||24,220||Jun 2014||616||25,423||Sep 2014||300||26,480||Dec 2014||137||27,240|
|Q1 total||413||Q2 total||1,203||Q3 total||1,057||Q4 total||750|
|79 FR 25176||1,001||79 FR 46306||576||79 FR 64031||776||80 FR 7685||1,062|
|Annual totals for 2014||Fed. Reg.||3,415||NICS||3,423||27,240|
|Jan 2015||271||27,511||Apr 2015||767||29,413||Jul 2015||856||30,973||Oct 2015||194||31,869|
|Feb 2015||105||27,616||May 2015||543||29,956||Aug 2015||552||31,525||Nov 2015||318||32,187|
|Mar 2015||1,030||28,646||Jun 2015||161||30,117||Sep 2015||150||31,675||Dec 2015||479||32,666|
|Q1 total||1,406||Q2 total||1,471||Q3 total||1,568||Q4 total||989|
|80 FR 26618||1,335||80 FR 45709||460||80 FR 65851||1,426||81 FR 6598||1,058|
|Annual totals for 2015||Fed. Reg.||4,279||NICS (-10)||5,416||32,666|
|Jan 2016||253||32,919||Apr 2016||860||34,807||Jul 2016||350||36,378||Oct 2016||440||37,346|
|Feb 2016||539||33,458||May 2016||765||35,572||Aug 2016||252||36,630||Nov 2016||227||37,573|
|Mar 2016||489||33,947||Jun 2016||456||36,028||Sep 2016||276||36,906||Dec 2016||430||38,003|
|Q1 total||1,281||Q2 total||2,081||Q3 total||878||Q4 total||1,097|
|81 FR 27198||1,158||81 FR 50058||509||81 FR 79098||1,379||82 FR 10185||2,365|
|Annual totals for 2016||Fed. Reg.||5,411||NICS (-16)||5,321||38,003|
A few caveats. The “addition” figure for April 2011 refers to all additions since December 2010. The “addition” figure for October 2012 includes what the FBI described as a “backlog” of 2,900 renunciant records, also included in the annual total for that year. I also gave an estimate of what the annual total would be without the backlog, even though some of the backlog may relate to other periods covered by the chart. Finally, the annual figures for 2015 and 2016 are smaller than the sum of the monthly additions because I subtracted out erroneous renunciant records submitted by U.S. state governments; see the Active Records in the NICS Index by State reports for 2015 and 2016.
Specifically, the government of Illinois submitted 9 records to the “Renounced U.S. Citizenship” category in 2015 or earlier, and 16 records in 2016, while North Carolina submitted one record in 2015 or earlier. These could be duplicates of records already entered by the State Department, for example if a renunciant moved back to the U.S., and the state government became aware of his citizenship status and thought they had to tell NICS. More likely, these are people who don’t meet the category definition in the first place, such as “freeman on the land” types who claim to be citizens of their state only and tried to renounce federal citizenship at the post office or by public notice in a newspaper.
Table of recent relinquishments by public figures
A variety of updates to the table this quarter. As Andrew Mitchel notes, there’s an Alexander Boris Johnson in the list (at page 27 of the pre-print); that is probably the floppy-haired Anglo-American imperialist ex-mayor of London, who claimed in 2006 and 2015 that he was going to renounce citizenship, but doesn’t actually appear to have got around to it until sometime in early 2016.
I am no longer including ex-citizens of 2014 and earlier vintage in the table. Bitcoin businessman Roger Ver and Ghanaian finance official Mona Quartey, both of whom renounced in 2014, have not yet appeared in the list, and given the length of time that has passed it is likely they never will. In the early years of the list, some people took nearly six years to show up — like author Shere Hite, who renounced in 1995 but didn’t get her name published until the much-delayed Q2 2001 list. However, in more recent years, if your name hasn’t shown up within about 18 months, it’s likely that State & the IRS just forgot about you entirely. You can always call up the Philadelphia IRS office and remind them to print your name, the way Mike Gogulski did.
|Giving up US citizenship||Appeared in
|Rachel AZARIA||Politician||Israel||Take office as Member of Knesset||January 2015||Q2 2016||Times of Israel|
|Jonathan TEPPER||Macroeconomic analyst||United Kingdom||FATCA & other U.S. tax reporting requirements||January 2015||Q1 2016||The New York Times|
|David ALWARD||Politician||Canada||Become Canadian consul-general in Boston||April 2015 or earlier||Q3 2015||Canadian Broadcasting Corporation|
|YANG Chen-ning||Physicist||China||Restore Chinese citizenship||April 2015||Q3 2015||Xinhua (China)|
|Andrew YAO Chi-chih||Computer scientist||China||Restore Chinese citizenship||Unclear||Q3 2015||Xinhua (China)|
|Alfred Oko VANDERPUIJE||Politician||Ghana||Stand for election to Parliament||August 2015||No||Starr FM (Ghana)|
|Philip RYU||Singer||South Korea||Serve in South Korean army||September 2015 or earlier||No||Money Today (South Korea)|
|Rachel HELLER||Writer||Netherlands||FATCA & other U.S. tax reporting requirements even when no U.S. tax is owed||November 2015||Q4 2016||Blog (will be included in TV news programme at a later date)|
|Susan WOOD||Unknown||Canada||FATCA & other compliance issues||November 2015||Q3 2016||Vancouver Sun|
|KANG Dong-suk||Violinist||South Korea||Restore South Korean citizenship||2015 (month not specified)||No||News1 (South Korea)|
|Pavel BURE||Ice hockey player||Russia||“US passport was no longer needed”||Early 2016 (month not specified)||Q4 2016||Sputnik News; Pravda Report|
|Neil (Teodoro) LLAMANZARES||Businessman||Philippines||Public opinion (his wife ran for President, but lost after he renounced)||April 2016||Q3 2016||Rappler (Philippines)|
|TAO Yuequn||Businessman||China||Unknown||April 2016 or earlier||No||Sina Finance|
|LEE Chih-kung||Physicist||Taiwan||Appointed Minister of Economic Affairs by President-elect Tsai Ing-wen||May 2016||Q3 2016||Apple Daily (Taiwan)|
|Ned (Nader) MANNOUN||Politician||Australia||Run for Australian parliament||May 2016 or earlier||Q4 2016||Liverpool Champion (Australia)|
|Karen ALPERT||Academic||Australia||FATCA & other compliance issues||June 2016||Q4 2016||Sydney Morning Herald|
|Yehuda GLICK||Politician||Israel||Take office as Member of Knesset||May 2016||No||Arutz Sheva (Israel)|
|Judy CHAN Ka-pui||Politician||Hong Kong||Run for Hong Kong Legislative Council||July 2016||Q3 2016||Apple Daily (Hong Kong)|
|Boris JOHNSON||Politician||United Kingdom||Taxes or politics or whatever||July 2016 or earlier||Q4 2016||Daily Mail|
|Kimi ONODA||Politician||Japan||Dual-at-birth, did Japanese-law “choice of nationality” long ago, didn’t know U.S. still considered her a citizen||October 2016?||No||Viewpoint (Japan)|
Media articles about the list as a whole (updated 10 Feb)
A couple of good articles
Media coverage of this quarter’s list mostly focuses on Boris Johnson, to the exclusion of the thousands of other newly-minted ex-citizens. The first article I’ve seen so far discussing the list and tax problems as a whole is this one by Caroline May over at The Daily Caller; unlike other outlets, they got some real value out of their interview with Andrew Mitchel. Unfortunately, citizenship relinquishment is a complex issue, and they seem to have misunderstood a point Mitchel was trying to make and condensed a quote from him down so far that it doesn’t make any sense:
When asked if he expected the expatriation trend to continue under President Donald Trump, Mitchel responded, “I believe that President Trump is against U.S. ‘birthright’ citizenship.”
Leaving aside the question of whether Republican proposals to restrict or eliminate jus soli have any chance of passing, none of the ones I’ve seen suggest doing so retroactively, meaning that any effect on expatriations wouldn’t show up until the next generation of babies reaches adulthood. H.R. 140, the Birthright Citizenship Act of 2017, sponsored by Steve King (R-IA), a fairly representative example, restricts jus soli to the children of citizens, non-citizen nationals (i.e. American Samoans), green card holders, or members of the armed forces, but explicitly states that it “shall not be construed to affect the citizenship or nationality status of any person born before the date of the enactment of this Act.”
Robert Wood at Forbes also wrote a good article covering the major themes: FATCA, bank account issues, the $2,350 fee, and the incompleteness of the list.
And a bunch of average-to-poor ones
Adam Taylor at the Washington Post at least mentions the problems that incompatible British & American tax breaks caused for BoJo, whereas Patrick Wintour at The Guardian, Katrin Bennhold at The New York Times, and Nikita Vladimirov at The Hill don’t even get to that level of detail. To be fair, however, all their articles avoid making any inaccurate, unsupported claims about the completeness of the list. In contrast, Laura Saunders at the Wall Street Journal, who should know better, misleadingly claims (emphasis mine) that “[t]he Treasury Department list includes the names of all people who renounced U.S. citizenship or long-term permanent residence in the latest quarter“. Elizabeth Piper at Reuters echoes the inaccurate “all” and LPR claims.
We’ve been pointing out here for nearly five years that many names go missing from the list — a phenomenon which did not seem to occur during the first decade of the list’s existence, but only began cropping up around 2006. It’s also quite clear that the list doesn’t just include people from “the latest quarter”, but those who renounced more than a year ago. And the IRS’ long-standing complaint — that they couldn’t include green carders in the list or enforce the exit tax against them because immigration authorities weren’t providing the IRS with SSNs or dates of residence — has never been resolved. There’s still nowhere to write your SSN on Form I-407 even after the recent redesign, and USCIS explicitly stated last year (emphasis mine) that when you file I-407, “we will provide only your name and the filing date to the IRS”.
The first article I’ve seen which tries to draw a line between the U.S. election and the list is this one by Deidre McPhillips of U.S. News. She got a quote from Andrew Mitchel telling her the real reason why so many people are giving up U.S. citizenship — the escalation of “offshore” penalties — but instead she concludes her article by discussing things that happened in a faraway country long after the people in the list made their decisions to give up citizenship:
However, today’s list that covers the last quarter of 2016 – the time period after Donald Trump was elected president – is nearly twice as long as the list from the last quarter of 2015.
Leading up to the U.S. election, a number of high-profile individuals, including Supreme Court Justice Ruth Bader Ginsberg and actor Bryan Cranston said, jokingly or otherwise, that they would leave the country if Trump was elected. A number of countries, including Canada and New Zealand, also launched campaigns promoting themselves as destinations for Americans looking to leave the country after the election.
The IRS reports include the names of expatriated individuals for which the Treasury secretary has received information, which is subject to logistical delay, but the annual totals of individuals choosing to expatriate has been steadily rising since 2012.
It’s strange that she notes that the list can be “subject to logistical delay” but doesn’t see how that affects her assumption that the growth in the list was driven by the U.S. election. Trump supporters over on Reddit have mostly jumped to the same erroneous conclusion as McPhillips, as have many Drudge Report readers. Russia’s Sputnik News also ran a cartoon by Ted Rall on the same theme, though as the attached blurb notes, “the trend began in 2011, while Trump was still hosting The Apprentice.”
“The worst thing about THAT country is that one of those groups is fixated on hunting down and torturing US persons worldwide, probably because they are jealous of our (us expats) freedoms.”
Jealous? Worse, that country suffers from a severe case of the inferiority complex.
@Eric here is the CNN article on Boris renunciation.
“Under the UDHR, changing one’s nationality is a human right; I find it incomprehensible how a human right eventually became a criminal act of some sort.”
Because the world’s paramount authority on human rights knows that it is.
Hey, how did we miss Paval Bure? It was on this last list?
Thanks for that, Ann#1! Might also be of interest to Vancouver Canuck fans. More:
@Ann#1 & Bubblebustin: thanks! I updated the table
Oh yeah, and two members of the Chinese Academy of Sciences (Yang Chen-ning and Andrew Yao) renounced US citizenship in order to restore their Chinese citizenship
Apparently this was a while ago (Yang showed up in the Q3 2015 list, didn’t check for Yao) but it didn’t get reported in the media until now. Will add to the table once I can figure out roughly when they actually had their appointment at the US conssulate
Okay, Xinhua says Yang renounced in April 2015 (not sure about Yao). Both are in the Q3 2015 list. Updated the table.
Chinese immigrants in the US are reacting just like born-and-bred American Homelanders (see the comments)
One guy in China also thinks it was just for tax reasons (Yang is 94 and Yao is 70; not sure if either is rich enough to be worried about the estate tax)
The Philippine Daily Inquirer published what appears to be the CLN of Philippine Foreign Secretary Perfecto Yasay. (The name Perfecto Yasay was in the latest list.) Shows an approval date on the same day as his renunciation appointment: 28 June 2016.
Again, we still have no evidence of anyone who relinquished later than August showing up in this quarter’s list, contrary to the narrative (seen in both CONservative and LIbEral Homeland media) that a bunch of people decided to renounce on the morning of 9 November and managed to get an appointment by the end of the year.
And, John Gaver’s at it again over on Wikipedia, claiming that the list only includes covered expatriates and that the Reed Amendment defines “covered expatriate”
A FOIA to State requesting the revenue collected from CLN fees collections should give a more accurate indication.
I challenge Brockers (Eric?) to file such a foia request!
It appears the information should be available – either by Post, or in aggregate.
Here’s a report I think I haven’t seen before.
Someone in 1998 asked the GAO to review available data on the tax compliance of U.S. citizens living abroad.
I rummaged around in my files to see if I could find an Examiner article written by John Gaver in 2014 but despite having saved the URL it now misdirects you to something totally unrelated. Anyway I had suggested in the comment section that the article be retracted because the information re: the Federal Register was inaccurate. He replied to my comment (using the name Solid_Facts) saying,
John Gaver will never be convinced he is wrong about this. However he does agree with all of us that CBT needs to be eliminated but he would advocate for Fair Tax rather than RBT.
Its at least plausible that the 100 random names he gathered from the 2006-2009 lists were primarily wealthy people, but that was more than a decade ago, i.e. at this point its now ancient history. Its faulty science to just assume those findings can be extrapolated to more recent times.
He obviously needs to do another sampling to reflect those who renounced due to Obama’s war on expats which started around 2010. The beginning of the pronounced uptick in renunciations would be a good place for him to analyze another random 100 names, say the 5 years from 2012-2016. He would likely find that the average wealth greatly decreased while the numbers of renunciants greatly increased. If he can’t be bothered to update his research its obvious he has preconceived conclusions and isn’t interested in correctly understanding the present situation. The fact that he still believes only covered expats are on the list and that the Reed Amendment defines that status (both easily refutable) indicates he really isn’t all that interested in the truth. Sort of reminds me of the mythster Robert Stack.
I asked him if he had researched lists AFTER FATCA came into being and he indicated that he would but I don’t know what happened after that. He wrote,
Maybe we here at Brock could help him out with our own anonymous survey?
Could any of our talented contributors set up a simple questionnaire for our renounced Brockers to answer, covered or uncovered, on or off the list?
That would be an interesting questionnaire or set of polls. I could start it with my husband … uncovered, on the list (2014) and he is very relieved to have a CLN. He’s just a rare bureaucratic error according to John Gaver who seems to be sticking to that theory in his 2017 wikipedia update.
Yes, seems like everyone I know who is on the list is not covered.
Also some people have appeared on the list before they filed their 8854 – and before their 8854 was due, so they couldn’t have become covered because they didn’t file it. There’s no way Treasury could have known at the time their names appeared if these persons were covered or not.
This part doesn’t make sense to me either . . .
Mr. Gaver seems to concede that inclusion of non-covered persons on the list does occur, but as a “bureaucratic error.” It can’t be a bureaucratic error, because the law does not stipulate that only covered expatriates are to appear on the list.
The law says things like “any individual,” “a copy of each [CLN to be provided to Treasury], “any,” “each,” no modifiers, and very clearly says , in 6039G(d)(3), “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).”
26 US Code 877A, referred to in the above quote, deals with *all* expatriates, covered and non-covered. The sections of 877A which deal specifically with covered expatriates make no mention of this, or any, list.
I didn’t see him give any sources that actually back up his claim that the list is for covered expatriates only. He does footnote his contention — but even the law he cites in his footnotes contradicts what he contends. The law stipulates that all individuals are to be on the list. It does not say that only covered individuals are to be on the list. (HIPPA, s. 512; 26 US Code 6039G).
We’ve been hearing the term “fake news” in the vernacular lately – unless I’m missing something (if so, please point it out), this Wikipedia article comes across to me like “fake scholarship.”
Yes “fake” is the new “it” word these days but sloppy will pass the test of time. So I’m going to call it “sloppy scholarship”. OTOH Mr. Gaver IS onboard about CBT being wrong so I’m good with that. The list is a farce on its own (incomplete, inconsistent and simply not to be trusted), so it’s rather like piling on to mislead people about how it is their name will appear on it. It’s Eric I trust on this, certainly not John Gaver.
Won’t be long before the Liberty List will be a shame for America. Just a hunch, but I don’t think it’s long for this world.
Even if John Gaver’s right that the list only includes covered expatriates, that is extremely far from proving that it only includes “wealthy people”, since you can become an “877(a)(2)(C) covered expatriate” by failing to certify under penalty of perjury on Form 8854 that you’ve crossed your ‘i’s and dotted your ‘t’s on the past five years of tax forms. I would go so far as to guess that the majority of covered expatriates fall into that category, and not just in recent years.
Here’s a known case of a farmer earning US$25,000/year appearing in the list in 1998
Would admin please direct me to where I can find further discussion of this paper on Brock?
Income Tax Compliance by US Citizens and US Lawful Permanent Residents Residng Outside the United States and Related Issues (1998)
It appears the recognition of the challenges faced by accidental Americans with regards to tax enforcement began long before the Obama administration.
Guy just posted his CLN on Reddit: (a)(5) renunciant, appointment in Bern in December 2016, approved 13 February 2017 (needless to say, not included in the Q4 Federal Register list)
@bubblebustin: some discussion in comments back in 2013
Thank you, Eric.
There doesn’t seem to be any lack of study on overseas Americans, just the impetus to do anything about it other than to FATCA us. Here’s another useless study:
2012 Taxpayer Experience of Individuals
Living Abroad: Service Awareness, Use,
Preferences, and Filing Behaviors