No time for a detailed analysis, but the Quarterly Publication of Individuals Who Have Chosen to Expatriate for Q4 2017 has just been placed on public inspection for printing in Friday’s Federal Register, ten days later than required by law.
I count 685 names in this list, bringing the total of “published expatriates” for 2017 to 5,133 individuals. In contrast, NICS added 1,017 people to the “Renounced U.S. Citizenship” category from October to December of last year, and another 353 in January. This quarter’s Federal Register list still does not include some public figures known to have given up US citizenship more than a year ago, including Japanese legislator Kimi Onoda and Ghanaian Deputy Minister of Finance Charles Adu Boahen.
| 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 |
| 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 | 427 | 42,387 |
| Mar 2017 | 763 | 39,487 | Jun 2017 | 344 | 40,672 | Sep 2017 | 349 | 41,676 | Dec 2017 | 306 | 42,693 |
| Q1 total | 1,484 | Q2 total | 1,185 | Q3 total | 1,004 | Q4 total | 1,017 | ||||
| 82 FR 21877 | 1,313 | 82 FR 36188 | 1,759 | 82 FR 50960 | 1,376 | 83 FR 5xxx | 685 | ||||
| Annual totals for 2017 | Fed. Reg. | 5,133 | NICS | 4,690 | |||||||
Fundamentally, nothing much has changed. After all the broken promises about how tax reform would save us, it just turned out to be another bonanza for accountants and lawyers. The IRS still can’t publish a simple list of names in a timely fashion. Trump and Tillerson’s underlings continue to spout the same insulting excuses as Obama and Kerry’s underlings did for the $2,350 rip-off.
People who can’t hide from this whole mess continue to face absurd wait times for appointments and CLNs (made worse by ongoing chaos in the State Department), while those who are able to hide have even stronger reasons to keep on hiding.
Ah- but this is about citizenship based taxation. This is about taxing businesses in America which are basically dutch. This isn’t about tax evasion anymore. So I think that even if Europe might embrace FATCA- they might increasingly have issues with CBT. This has been my major gripe all along. Its not the transparency- its the fact that America is taxing anything that moves and claiming it as their own.
“I think that even if Europe might embrace FATCA- they might increasingly have issues with CBT.”
The G5 wrote to Mnuchin in December, raising concerns particularly about this new
GuiltyGILTI tax.Individual CBT is presumably not a problem for the government of a country with USC residents. Very little CBT gets paid, and what does get paid is paid by the USC, on top of local tax – not instead of local tax.
GILTI, the excise tax, and BEAT – those are the three issues the G5 expressed concern about. The transition tax as applied to a USC owner of a foreign corporation would be a tax on the individual, as I understand it.
Other countries with USC residents might not be worried that CBT infringes immediately upon their tax base because it happens at the individual level, but they still might be concerned about the general concept of wealth being siphoned beyond their borders. (Think of US C.G tax on the sale of a principal residence or the so-called “exit” tax, for instance.) Governments have a tendency to take their taxation jurisdiction very seriously.
Also, once they figure it out, they might object to the US getting into the tax haven business after bringing all the Swiss banks to heel. On second thought, maybe not. Lots of foreign politicians make good use of those Delaware corporations.
Can anyone explain to me why USC owners of foreign corporations are treated by the US as Controlled Foreign Corporations? Is it an option which they chose at some time in the past, or is it US policy to treat all corporations with USC personnel as Controlled Foreign Corporations?
maz57 – The US tax haven business is not news to Europe. Pre Panama Papers, the squirmy states used to advertise their services a lot in the European media. And the EP’s PANA mission last summer made a point of meeting with NH, Delaware, etc. To no avail, needless to say.
“…they still might be concerned about the general concept of wealth being siphoned beyond their borders.”
I think they’re concerned about competitive advantage and transfer taxes. But CBT has been there for decades, agreed in every US tax treaty. Nothing’s changed, and I see no indication that other countries regard it with any concern.
http://taxprof.typepad.com//taxprof_blog/2018/02/number-of-americans-renouncing-their-us-citizenship-fell-in-2017-the-first-decline-in-five-years-.html
The author of the blog above doesn’t opine about the reasons for the decline.
But as you note @Eric;
“….People who can’t hide from this whole mess continue to face absurd wait times for appointments and CLNs (made worse by ongoing chaos in the State Department), while those who are able to hide have even stronger reasons to keep on hiding….”
The absurd and human rights violating fees to both renounce AND now to relinquish, plus the State Dept.’s ongoing work to maintain the bottleneck/barrier to exercise the legal right to renounce continues to reduce the numbers who can afford to go through the formal process as well as significantly delay and cap the numbers of those who can even manage to get an appointment to do so.
And who knows how many have just decided that they’ll lay low instead. Those without the US birthplace marker living outside the US can for now just stay unidentified.
The Honour Roll will be late for the seventh quarter in a row
https://www.federalregister.gov/public-inspection/2018/04/27
https://www.federalregister.gov/public-inspection/2018/04/30
Steven Mnuchin hasn’t managed to get a single list out on time. (Not sure if his fault or Gladys Perez-Hernandez’s fault or Maureen Manieri’s fault.)
Casual lawlessness continues: the Honour Roll will be at least one week late.
https://www.federalregister.gov/public-inspection/2018/05/04