Liberty and justice for all United States persons abroad

1,759 published expatriates in Q2 2017 Federal Register list

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

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

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.

Name Occupation Other
citizenship
Giving up US citizenship Appeared in
Federal
Register
?
Source
Reason Date
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)

Back to table of contents

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
FR
citation
Addi-
tions
FR
citation
Addi-
tions
FR
citation
Addi-
tions
FR
citation
Addi-
tions
Year-end
total
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
Month,
year
Addi-
tions
Month-end
total
Month,
year
Addi-
tions
Month-end
total
Month,
year
Addi-
tions
Month-end
total
Month,
year
Addi-
tions
Month-end
total
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:
~1,700
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

Back to table of contents

Conclusion

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.

71 thoughts on “1,759 published expatriates in Q2 2017 Federal Register list

  1. 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

    http://www.washingtontimes.com/news/2017/aug/24/ex-patriots-should-not-be-taxed-in-foreign-lands/?utm_campaign=shareaholic&utm_medium=twitter&utm_source=socialnetwork
    ____________________________________________________________________________________________________
    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.

    https://www.facebook.com/republicansoverseas/photos/pcb.726977897486008/726974060819725/?type=3&theater
    _______________________________________________________________________________________________________

    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”
    TWITTER.COM

  2. @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).

  3. 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.

  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. “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.

  9. “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.

  10. “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.

  11. Karen:

    “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.

  12. 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.

    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.

    http://www.newdaily.co.kr/news/article.html?no=358076

  13. https://www.law.cornell.edu/uscode/text/26/6039G#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.

    Quarterly reminder: the IRS deliberately refuses to obey Subtitle F, Chapter 61, Subchapter A, Part III, Subpart A of the “Internal” Revenue Code
    https://www.federalregister.gov/public-inspection/2017/10/30

    But they expect you to obey it. Laws are for little people.
    https://www.law.cornell.edu/uscode/text/26/6038D

  14. 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.

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