1,313 published expatriates in Q1 Federal Register honour roll; 1,484 renunciants added to NICS for same period

The Quarterly Publication of Individuals Who Have Chosen to Expatriate for Q1 2017 has just been placed on public inspection for printing in Wednesday’s Federal Register, ten days later than required by law. This quarter’s list contains 1,313 “published expatriates”, in contrast to the FBI’s NICS gun control database which counted 1,484 renunciants for the first three months of the year (and another 460 in April).

NICS only includes people who renounce citizenship under 8 USC § 1481(a)(5). In other words, it is supposed to cover a smaller population than the Federal Register list, which includes § 1481(a)(1) – (4) relinquishers as well. So it’s clear that not all ex-citizens get their names published in the Federal Register, though there seems to be neither rhyme nor reason behind that long-standing phenomenon — (a)(5) renunciants & (a)(1) relinquishers, rich & poor, covered & uncovered expatriates, and filers & non-filers of 8854 alike are among both the published and the unpublished.

All we can say for sure is that either the State Department is not forwarding some CLNs to the IRS, or the IRS is not publishing the names from all the CLNs they receive. (Given that State should be forwarding CLNs to both the FBI and the IRS, and the FBI clearly have been receiving CLNs, I’d guess that the problems are the IRS’ fault.) It’s clearer why tens of thousands of people who abandon their green cards each year don’t show up in the list either: USCIS isn’t providing the IRS with the information they need about those folks, as we’ve discussed in more detail previously.

We still can’t tell whether the U.S. election results are having any effect on the numbers, because it’s not clear when the people named in this quarter’s list actually went and paid that $2,350 to the U.S. government — I’m not having much luck matching the names in this quarter’s list to media reports. One person in this quarter’s list is known to have relinquished in June 2016, but I can’t find any others who have previously spoken with the media about giving up U.S. citizenship. If you know the date anyone in this quarter’s list (whether yourself or a public figure) had their final appointment at the consulate, please leave a comment.

Table of contents

1. Table of recent relinquishments by public figures
2. Comparison with NICS
3. Conclusion

Table of recent relinquishments by public figures

A few more additions to the table this month. Ghanaian Deputy Finance Minister Charles Adu Boahen started the procedure to renounce his U.S. citizenship in December 2016, and said the U.S. Embassy in Accra made him attend three interviews for some reason. Chris Hart, a musician in Japan, acquired Japanese nationality and so will have to provide the Japanese government with his CLN with two years, but it’s not clear whether he’s started the process of obtaining one yet. I have not yet included Randall Dietz of Australia in the table — the Sunshine Coast Daily reported that he is trying to raise funds to pay for the State Department’s absurd CLN fee, but he does not seem to have actually renounced nor performed any other relinquishing act yet.

Unfortunately, only one person from the table showed up in this quarter’s list — Frank Alpert, who renounced nearly a year ago. It’s likely that some people in the list renounced later than he did, though it’s not clear whether we’re starting to see November & later renunciations yet. Update, 10 May: In a comment, Shadow Raider points out one famous name I missed: the president of Peru, who renounced way back during campaign season in November 2015. Also, three other Brockers in the list mention that they had their final consular appointments in January, August, and the last quarter of 2016. So State and the IRS are still clearing up a backlog from as long as eighteen months ago, though it looks like post-election renunciations are finally starting to come in — with no evidence of any sudden slowdown or speed-up, contrary to all the media hype.

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.

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Comparison with NICS

The below table lists the yearly additions to NICS from 2006 to 2010, and monthly additions for 2011 up through the present, 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 some archiving service 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.

Unfortunately, some previously-saved reports (e.g. the February 2017 report) seem to have disappeared from the Internet Archive. I’m not sure whether this is a temporary issue or what.

Same caveats as previous editions of the table. 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.

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Conclusion

With last month’s hearing on FATCA, Congress finally took the first steps towards formally acknowledging our issues — over the vociferous objections of the Democratic witness who claimed that emigrants giving up citizenship because of bad laws don’t matter because immigrants who aren’t affected by those laws continue to naturalise. However, a first step is not a solution. Neither Congress nor the president have yet released a concrete tax reform plan which addresses our issues, and even if they do there’s no guarantee they can pass it — particularly if Democrats oppose the whole thing and certain Republican senators want to tweak it to ensure the diaspora keeps getting screwed.

Until there’s a solution in sight, people will simply keep on snapping up all available renunciation appointment slots.