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1,376 published expatriates in Q3 2017 Federal Register list of people giving up US citizenship

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The Quarterly Publication of Individuals Who Have Chosen to Expatriate for Q3 2017 has just been placed on public inspection for publication in Thursday’s Federal Register, three days later than required by law. By my count, this list contains the names of 1,376 people who renounced or otherwise relinquished US citizenship under any paragraph of 8 USC § 1481(a), as compared to 1,004 people who renounced US citizenship (under 1481(a)(5) only) added to the FBI’s National Instant Criminal Background Check System (NICS) in July, August, and September.

Following Q3 & Q4 2016, this is only the second time since 2011 that we’ve had two quarters in a row of Federal Register numbers being significantly higher than NICS numbers, the way they should be every quarter. Even then, the Federal Register list is far from complete: contrary to some media reports, it’s basically impossible that the list includes people who give up their green cards, and no one has ever identified a single green card abandoner in the list, despite the message at the top claiming that “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 people named in this list probably completed the State Department’s painfully slow and expensive formalities to apply for a Certificate of Loss of Nationality around mid-year at the latest, but that’s just a guess. I can confirm that one name in this quarter’s list belongs to a man known to have relinquished in April 2016 or earlier. For the US government, that’s positively speedy — last quarter’s list had relinquishers from 2013 and 2014.

As always, after the jump you can find discussion of recent media reports about relinquishers, as well as a table of past NICS and Federal Register statistics.

Table of contents

  1. Recent media reports about relinquishers
  2. Comparison with NICS
  3. Conclusion

Recent media reports about relinquishers

There have been a few recent media reports about public figures who have given up US citizenship, but none of their relinquishments actually seem to have occurred last quarter. Tao Yuequn, founder of contact lens manufacture OrthoK, who restored his Chinese citizenship at the latest by April 2016, is in this quarter’s list. I don’t know when others in the list made their final visits to US consulates to apply for Certificates of Loss of Nationality, because I’m not having much luck matching any of their names to media reports. Last quarter’s list had one name of a man who applied for his CLN as recently as March 2017 or later, so my best guess is that this quarter they might be starting to list the names of Washington-approved relinquishers from around mid-year.

The daughter of South Korean Minister of Foreign Affairs Kang Kyung-hwa is in the process of applying to get her South Korean citizenship back, but hasn’t yet requested a CLN; according to a report from last month (in Korean), she’s still waiting for a police certificate from the US before the South Korean side formally approves her restoration of citizenship. Once her citizenship is restored, she will have twelve months to give the South Korean government a CLN, or at least proof that she’s applied for one — see our previous post for an explanation of the procedure and a translation of the relevant South Korean regulations.

Jazz drummer Alvin Queen, who showed up in the Q3 2016 list, doesn’t seem to have spoken up last year about his decision to relinquish US citizenship after holding dual citizenship with Switzerland for three decades, but he was in the news last week when the Department of Homeland Security decided to deny him entry to the US over a half-century-old drug arrest which resulted in no charges. Mr. Queen states that he gave up citizenship “to make life simpler at tax time”. Mr. Queen’s manager Jean-Pierre Leduc apparently thought it would be a bright idea to call Senator Chuck Schumer to try resolving the situation, since Mr. Queen was born in Schumer’s state. That must have been a rather awkward phone call: Schumer sponsored the Ex-PATRIOT Act, which would have punished people who gave up citizenship to make life simpler at tax time by banishing them permanently.

Finally, Hermitage Capital founder Bill Browder, who relinquished in 1997 and showed up in the Q3 1998 list alongside Lithuanian president Valdas Adamkus and South Korean apple farmer Choi Yongtak, also briefly had his ESTA travel authorisation revoked due to an Interpol diffusion notice filed by Russia. He tweeted later to state that he got it restored; news reports say that someone at DHS manually reviewed the situation in response to the media coverage, suggesting that the original revocation was due to some automated process. Mr. Browder was born in Illinois, but apparently he was savvy enough to know that calling FATCA-natic Dick Durbin wasn’t the best way to get his problem solved.

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
Alvin QUEEN Jazz drummer Switzerland “To make life simpler at tax time” 2016 (month not specified) Q3 2016 Billboard (US)
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 Q3 2017 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.

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 284 41,960
Feb 2017 344 38,724 May 2017 381 40,328 Aug 2017 326 41,327 Nov 2017    
Mar 2017 763 39,487 Jun 2017 344 40,672 Sep 2017 349 41,676 Dec 2017    
Q1 total 1,484 Q2 total 1,185 Q3 total 1,004 Q4 total  
82 FR 21877 1,313   82 FR 36188 1,759 82 FR 50xxx 1,376    
Totals so far for 2017 Fed. Reg. 4,448 NICS 3,957 41,960

Conclusion

Tomorrow we may get some good news about the US’ treatment of its diaspora, or we may not. Even if we do, there’s still a long, hard road ahead for US persons in other countries trying to live normal lives like their neighbours. Territorial Taxation for Individuals faces opposition from Democrats, and it’s unclear how valiantly House Republicans will defend it if their Homeland base, fed on a diet of mendacious coverage like this, objects to “expats getting huge tax breaks” while they suffer attempted repeal of the state and local tax deduction or the mortgage interest deduction. Also, any proposal offering even a hint of sanity for the diaspora, whether that proposal come from Republicans Overseas, American Citizens Abroad, or Democrats Abroad, will likely face bipartisan opposition from diaspora-hating Senate Finance Committee members such as Chuck Grassley, Bob Casey, and Bill Nelson.

Furthermore, as USCitizenAbroad points out in a comment, FBAR repeal does not appear to be under consideration. FATCA IGAs and all the bank machinery to enforce them will remain in place until someone explicitly burns them all to the ground. No one knows what will happen to things like the Section 2801 inheritance tax on US heirs of non-compliant expatriates (which House Republicans explicitly chose to retain during their unanimous vote two years to repeal the estate tax, and which unlike the estate tax does not have any $5.5 million exemption). The Reed Amendment lurks in the background, unenforced but also unrepealed.

It’s been eight years since the 2009 “Offshore” Voluntary Disclosure Program started the painful and intimidating audits which ultimately led to five-figure fines against minnows who had missed two figures per year of US taxes, and the FATCA hammer slamming every bank in sight in alleged pursuit of tax evaders. Some people have exhausted their reserves of energy, and don’t have the wherewithal to hang on for another year or however long this all takes. Some people have lost all faith in the US government, and don’t trust it not to yank the rug back out from under them once they’ve gotten comfortable. Non-Americans will continue to be wary of doing business with Americans abroad, after seeing how easily the US government used those Americans as Trojan horses to breach other countries’ sovereignty and invade their privacy.

A solution would be welcome, but the US has already done irreversible damage to its diaspora, shattering good will and taxpayer morale. The names in this list are a reminder of that.

93 thoughts on “1,376 published expatriates in Q3 2017 Federal Register list of people giving up US citizenship”

  2. Yay! I made the list! My relinquishment date was 9 August 2017.
    It feels great to be “named and shamed”! LOL

  4. Well if they’re going to ban anybody from the country for involvement in tax evasion, it should be the Liechtenstein royals.

  5. So, a slight dip in renunciations / relinquishments in 2017 (extrapolating for Q4), relative to what may have been a peak in the last couple of years. I guess we’re getting the cohort of people who may have thought about waiting to see what Trump would do? (Of course these would be the ones who didn’t wait.)

  6. Thanks for posting this, Eric. My son and I are both on the list (renouncements in April and June of this year); we had each submitted our paperwork before last year’s election.

    “the US has already done irreversible damage to its diaspora, shattering good will and taxpayer morale. The names in this list are a reminder of that.”

    This.

    The U.S. lost four of us in one family, each of whom would have been delighted to remain a U.S. citizen and serve as an informal ambassador. Given current events, I can’t imagine the U.S. can afford to squander any more resources, especially goodwill abroad. Far from feeling shamed, we each feel relief at simplifying our lives in Canada, which for all of us is home and not a “foreign country”, especially for my kids, who were born here.

  9. Good work again, Eric!

    I have (only) found two pairs of duplicate names this time — one with surname LIANG and one with surname SELINGER.

  11. The Hill’s article isn’t so bad
    http://thehill.com/blogs/blog-briefing-room/358277-record-number-of-americans-renouncing-citizenship-in-2017

    But the comments and Twitter replies are terrible anyway
    http://thehill.com/blogs/blog-briefing-room/358277-record-number-of-americans-renouncing-citizenship-in-2017?mode=comments#disqus_thread
    https://twitter.com/thehill/status/925892716633800704
    https://twitter.com/thehill/status/925914626881150976

    For some reason I don’t understand, there are a bunch of insulting responses from Bitcoin promoters
    https://twitter.com/Crypto2U/status/925864819214893057
    https://twitter.com/ThoriumWealth/status/925905195111993344

    As well as other generic nationalist butt-hurt:
    https://twitter.com/theusaclub/status/925841085603237889

  13. I reckoned there would be a slow down in renunciations. Anyone clued up enough to be contemplating renouncing would surely be clued up enough to know what is going on right now and that their renunciation might not be necessary.

  14. The guy the Bloomberg writer took a pop at seems to be a London banker. Could he sue for defamation in UK courts I wonder. I hope he reads Bloomberg

  15. Chinese- & Korean-language media are running translations of the Bloomberg article (without the “Quitter” line – insulting pun sounds even stupider if you have to include a translator’s note with it)

    http://www.newspim.com/news/view/20171102000045
    https://tw.news.yahoo.com/%E5%A4%96%E5%9C%8B%E6%9C%88%E4%BA%AE%E6%AF%94%E8%BC%83%E5%A4%A7-%E7%BE%8E%E5%9C%8B%E6%94%BE%E6%A3%84%E5%9C%8B%E7%B1%8D%E4%BA%BA%E6%95%B8%E5%B9%B4%E6%88%90%E9%95%B726-044016808.html

  16. @Bubbles…….Good morning.

    “Americans are renouncing because of FATCA:”

    As you and others know….I have been quick to defend Candidate Trump, President Trump and the Republican Party. But there was a limit to that and I am on record as stating that patience would run out in September and it has.

    Americans are renouncing because;

    1. President Trump FAILED to exercise his Executive Authority and STOP sigining new IGA agreements.
    2. President Trump FAILED to exercise his Executive Authority by instructing his Secretary of the Treasury to exercise the Secretary’s authority granted by Congress under the Bank Secrecy Act to index the $10,000 FBAR requirement with inflation and to declare that accounts held in countries with robust AML and KYC rules were exempt from reporting!!

    The very first person who renounced on October 1, 2017 renounced because of President Trump.

    Today, President Trump OWNS the plight and is responsible for the very harm inflicted on every so called deemed American outside the USA. The baton or rather whip has now been handed from Obama to Trump and Trump has grabbed the whip and it is his agency’s and his secretarys that are doing the whipping.

    I say this as someone who has defended the man 100%.

    It is indeed a very sad day.

  19. @Barbara, someone needs to call them on the carpet for that misleading headline.

    Did the writer examine the list of names to determine who was rich and who was not rich?

    What is the definition of “rich?”

  20. Holly Gilliam, daughter of Terry Gilliam of Monte Python Fame, is on the list. Terry renounced very publically in 2006 and had to do the 10 yrs tax stint.

  21. My wife renounced in early September 2017 in Frankfurt and hasn’t received her CLN, and she also didn’t make the Q3-17 Federal Register list. At her appointment, she was told that currently the turnaround for the CLN was 6-8 weeks only. More than 8 weeks have passed though. Does anyone have an up-to-date estimate of the turnaround for Frankfurt?
    (Germans won’t issue her citizenship without the CLN, so until that arrives she’s stateless and cannot travel).

  22. @Barbara, @ Moderators….I think we need to start headline linking to these FALSE articles and set the record straight.

    I just emailed the following to Newsweek and suggest others do as well.

    This headline “More Rich Americans Are Giving Up Their Citizenship to Avoid Taxes” is false and misleading. Did the writer actually review the list and research the names on the list? The TRUTH is that most of the names were simply Average Americans who gave up their US Dual Nationality because they were shut out of jobs, opening basic bank accounts or threatened by divorce by a non-US Citizen spouse.

    You should better research this issue by going to the Isaac Brock Society;

    https://isaacbrocksociety.ca

    And by looking at the study conducted by Democrats Abroad!!
    http://www.democratsabroad.org/taxation_report_2017?utm_campaign=glb_ttf_report&utm_medium=email&utm_source=democratsabroad
    http://www.democratsabroad.org/taxation_report_2017?utm_campaign=glb_ttf_report&utm_medium=email&utm_source=democratsabroad

    STOP THE LIES AND CORRECT YOUR REPORTING!!!

  23. Wikipedia says of Terry Gilliam:

    “As a result of renouncing his citizenship, Gilliam is permitted to spend only 29 days per year in the United States, fewer than ordinary British citizens.”

    I wasn’t told of such a rule. Does it really exist?

  24. Graham Lanktree, that’s the guy at Newsweek. Maybe somebody could find his contact details and have word with him about his appallingly inaccurate headline.

  25. plaxy – that’s an old rule that applies only to those who renounced before June 17, 2008. It only applies for the first 10 years after expatriation, so if Gilliam renounced in 2006, he should be past the 10 year period by now.

    From form 8854 instructions (in the section for those who renounced between 2004 and 2008):

    Tax consequences of presence in the United States after expatriation.
    If, for any tax year during the 10-year period in which you are otherwise subject to section 877, you are present in the United States for more than 30 days in a calendar year ending in such tax year, you will be treated as a U.S. citizen or resident for that tax year. You will be subject to U.S. tax on your worldwide income unless the following exception applies.

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