Apologies for not posting in a while. The Quarterly Publication of Individuals Who Have Chosen to Expatriate for Q2 2017 has just been placed on public inspection for publication in Thursday’s Federal Register, four days later than required by law.
By my count, this list contains the names of 1,759 people who renounced or relinquished US citizenship under any paragraph of 8 USC § 1481(a), as compared to 1,185 renunciants (under 1481(a)(5) only) added to NICS in April, May, and June (update, 4 August 2017: and another 329 in July). The number of names in the Federal Register continues to show an upward trend, with the four-quarter moving average rising by 48% from 1,026 a year ago to 1,517 as of this quarter.
Homeland pundits continue to misunderstand what’s driving these numbers: witness this Orlando Sentinel op-ed, which tries to blame the Q4 2016 spike on Trump’s election and other issues which are of great interest to Homelanders but are hardly the centre of attention for citizens of other countries who have lived abroad most of their lives. In fact, it wasn’t until this quarter’s list that we finally started seeing names of people who verifiably gave up US citizenship since Trump’s win — for example Chris Hart, who became a citizen of Japan sometime around March, and whose name shows up at page 15 of the public inspection PDF. However, this quarter’s list also contains names from other Certificates of Loss of Nationality which took as long as four years to finish working their way through the system.
Table of contents
Table of recent relinquishments by public figures
I haven’t been able to dig up any media articles during the past quarter confirming new relinquishments by public figures. Please leave a comment if you’ve seen any. One person who tweeted about his decision to renounce US citizenship back in May showed up in this quarter’s list. Additionally, some newspaper articles stated that the eldest daughter of newly-appointed South Korean foreign minister Kang Kyung-hwa planned to renounce US citizenship, but I haven’t been able to confirm whether she’s actually gone through with this.
Comparison with media reports continues to show long delays and a certain proportion of omitted names. 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. These days, I usually say that if your name hasn’t shown up within about 18 months, it’s likely that State & the IRS just forgot about you entirely, and that you should call up the Philadelphia IRS office and remind them to print your name, the way Mike Gogulski did.
However, this quarter’s list gave us two blasts from the past: René González of Cuba (who made his final visit to the US consulate all the way back in May 2013) and Ghana’s former Deputy Finance Minister Mona Quartey (who renounced in July 2014), so long ago that I’d removed them from the table. The IRS were so slow that by the time they finally got around to printing Quartey’s name, she’d already stepped down from the government positions for which she renounced US citizenship in the first place.
|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 US 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)|
|Pedro Pablo KUCZYNSKI||Politician||Peru||Run for president||November 2015||Q1 2017||El Comercio (Peru)|
|Rachel HELLER||Writer||Netherlands||FATCA & other US tax reporting requirements even when no US tax is owed||November 2015||Q4 2016||Blog (will be 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)|
|Yehuda GLICK||Politician||Israel||Take office as Member of Knesset||May 2016||Q2 2017||Arutz Sheva (Israel)|
|Karen ALPERT||Academic||Australia||FATCA & other compliance issues||June 2016||Q4 2016||Sydney Morning Herald|
|Frank ALPERT||Academic||Australia||FATCA & other compliance issues||June 2016||Q1 2017||Sydney Morning Herald|
|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”, didn’t know US still considered her a citizen||October 2016?||No||Viewpoint (Japan)|
|Charles Adu BOAHEN||Politician||Ghana||Become Deputy Minister of Finance||Early 2017||No||Ghana Guardian|
|Chris HART||Musician||Japan||Naturalise in Japan||March 2017 or later||Q2 2017||Sports Hochi (Japan)|
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.
Fortunately, the Internet Archive seems to have solved the earlier problem with disappearing reports (e.g. the February 2017 report). It seems to have been a transient issue with one file server.
|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|
|Jan 2017||377||38,380||Apr 2017||460||39,947||Jul 2017||329||41,001||Oct 2017|
|Feb 2017||344||38,724||May 2017||381||40,328||Aug 2017||Nov 2017|
|Mar 2017||763||39,487||Jun 2017||344||40,672||Sep 2017||Dec 2017|
|Q1 total||1,484||Q2 total||1,185||Q3 total||Q4 total|
|82 FR 21877||1,313||82 FR 36xxx||1,759|
|Totals so far for 2017||Fed. Reg.||3,072||NICS||2,998||41,001|
In spite of the obscene $2,350 fee, accidentals and emigrants continue snapping up all available citizenship relinquishment appointment slots, and consulates continue to process CLNs as fast as they can … which evidently is not very fast. Ongoing organisational problems at the State Department mean this situation probably will not improve any time soon. Vague promises of “territorial taxation” from diaspora-hostile politicians like Orrin Hatch mean little unless and until we see concrete legislation surviving its trip through the Senate Finance Committee without being mutilated. People want to get on with their lives in the countries they call home, not sit around waiting for news out of the capital of a foreign country.
Washington TImes./ Congress must stop taxing income that U.S. citizens earn in foreign lands // Grover Norquist- IRS double taxes many Americans working overseas / RNC Resolution Supporting Territorial Taxation For Individuals
Republicans Overseas .
The RNC Resolution Supporting Territorial Taxation For Individuals (TTFI) Replacing Citizenship-Based Taxation (CBT) adopted by the RNC Resolutions Committee unanimously yesterday is released for the entire RNC membership to review and vote tomorrow. Since the White House is on board with our Territorial Taxation for Individuals proposal, the resolution is expected to win full RNC approval on Friday.
Grover Norquist on Twitter
“Overlooked in much of the tax reform debates is how IRS double taxes many Americans working overseas. https://t.co/iQHseCSe6j”
41,327 renunciants in NICS as of 31 August 2017 (+326 during August)
Report was much later than usual this month. Finally showed up sometime this week, not sure what day.
Renounced U.S. Citizenship 41,327 ??
What time period ?
@Jak Dac: 41,327 is the total number of “renounced U.S. citizenship” entries they’ve added to NICS since NICS got started in 1998. In 1998 they added an initial batch of about 12,000 entries, then didn’t add anything more to the “renounced U.S. citizenship category” until 2005, then added about 29,000 entries since then. +326 refers to the latest monthly update (i.e. they added 326 renunciants during August 2017).
This has got to get out there that number will make people look
May be worth rewording and put it up on FB Citizenship Taxation https://www.facebook.com/CitizenshipTaxation/
41,676 renunciants in NICS as of 30 September 2017 (+349 during September, +1,004 during Q3)
Thank you @Eric for keeping us apprised of the numbers. Much appreciated!
I think the small number of renunciations proves that millions of accidentals know how not to be seen, staying under the radar. No wonder there were so few submissions to petitions and letter-writing campaigns.
Bingo. That’s why I’m not too interested in renunciation. Costs US$2350 and puts your name on a list sent to the IRS. Much easier to do nothing when you’re protected from penalties by your country of residence and citizenship.
Yup, the best way to ensure that CBT and FATCA fail is for millions of expats to continue to do exactly what they are already doing; totally ignoring the whole unworkable, unenforceable mess.
I doubt that millions of accidentals and expats are making a conscious, reasoned decision to stay out of the US tax system. I think they either have no idea, or when they do hear rumour of such things, it seems so patently absurd that they refuse to believe it.
It’s an interesting mismatch – estimated 9 million Americans, a million or so compliant, and zero enforcement actions arising as a result of FATCA.
What a waste of (other countries’) money.
“the best way to ensure that CBT and FATCA fail is for millions of expats to continue to do exactly what they are already doing; totally ignoring the whole unworkable, unenforceable mess.”
Unworkable and unenforceable, and likely to drift into the same undead status as CBT, but on its way to half-life FATCA has spawned all these damnable IGAs, which for some people in some countries are having all-too-real consequences.
FATCA needs to go, and the US needs to agree to sign up to CRS and only get reports on accounts held in other countries by accountholders not resident in the reporting country. And not treat place of birth as grounds for reporting people as suspected criminals, like some hideous pogrom from the Dark Ages.
“That’s why I’m not too interested in renunciation. Costs US$2350 and puts your name on a list sent to the IRS.”
The $2350 is the problem. Lists of non-US-resident non-US-citizens sent to the IRS are irrelevant.
As are lists of non-US-resident non-US-citizens not living in the US, sent to the FBI so they can make sure none of us can sneak into America and buy guns and commit mass murder.
“FATCA needs to go, and the US needs to agree to sign up to CRS and only get reports on accounts held in other countries by accountholders not resident in the reporting country. And not treat place of birth as grounds for reporting people as suspected criminals, like some hideous pogrom from the Dark Ages.”
The US should only get reports on people physically resident in the US. (US citizens living in one country and banking in a second should have their banking details sent only to the country where they physically reside). Unfortunately, CRS is completely compatible with CBT – if the US joins CRS (not likely) and continues CBT, they’ll just define all citizens as US tax-residents and banks will be required to treat all US citizen accounts as reportable, regardless of where the US citizen lives. The advantage of CRS, though, is in how it is enforced. Enforcement under CRS (and under some Model 1 FATCA IGAs) depends on local law, not US extra-territorial law. So, under CRS, banks aren’t worried about 30% US withholding if they are non-compliant.
“Unfortunately, CRS is completely compatible with CBT – if the US joins CRS (not likely) and continues CBT, they’ll just define all citizens as US tax-residents and banks will be required to treat all US citizen accounts as reportable, regardless of where the US citizen lives.”
I should have been clearer. I would like to see changes to CRS also. I’ll rephrase and expand:
The US needs to agree to sign up to CRS
– and CRS needs to be amended so that only accounts belonging to non-residents of the reporting country are reported on. The obligation for banks in one country to sleuth out all countries of tax-residence should be dropped.
Any individual CRS country can only have knowledge of whether an accountholder is or is not resident in that country. If the US signed up to CRS, it would need to sign bilateral agreements with each country it wanted reports from, and, more significantly, wanted to report to.
If FATCA is repealed and the US still refuses to sign up to CRS, that would be ok with me.
Kang Kyung-hwa’s daughter appears to be actually planning to go through with giving up US citizenship. She applied to the South Korean government for restoration of citizenship, and got a police report from the US (a document required by the South Korean side) in August, says a news report from a couple of weeks ago. Once her South Korean citizenship is restored, she has to show her CLN (or at least proof that she’s applied for one and is waiting for it) to the South Korean government within two years.
Quarterly reminder: the IRS deliberately refuses to obey Subtitle F, Chapter 61, Subchapter A, Part III, Subpart A of the “Internal” Revenue Code
But they expect you to obey it. Laws are for little people.
Q3 list is out. About 1,370 published expatriates.
Thank you, Eric. By my calculations, that’s 4442 so far this year. With only 962 needed in Q4 to exceed last year’s total, 2017 promises to be another record-breaking year.