Part A – The Good news!! – The Fee For A CLN Is Lower

I noted in my post of March 5, 2026 that the reduction in fees for a Certificate of Loss of Nationality was in the final regulatory stage.

The fee reduction for a CLN  from $2350 to $450 USD will  be in effect on April 13, 2026.

https://www.federalregister.gov/documents/2026/03/13/2026-04931/schedule-of-fees-for-consular-services-fee-for-administrative-processing-of-request-for-certificate

(As reviewed in the Appendix to this post, the delay in the fee reduction had been extensively discussed in my January 4, 2026 post.)

A “Certificate of Loss Of Nationality” will be less expensive and therefore more available

On March 13, 2026 the State Department published in the Federal Register a “Final Rule” which:

… adjusts the Schedule of Fees for Consular Services by reducing the fee for Administrative Processing of Request for Certificate of Loss of Nationality of the United States from $2,350 to $450.

This “Final Rule” is to take effect 30 days from the date of publication. This  means that the renunciation fee will be $450 effective April 13, 2026.

The fee reduction is NOT retroactive

The Notice is clear that the fee reduction is prospective and NOT retroactive.

To learn more …

Here is the pdf to the State Department announcement of the fee reduction for a CLN from $2350 to $450.

2026-04931

Commentary on X …

 

Part B – The Better News – The Message Is Getting Through To The Government

The State Department’s “Final Rule” acknowledges the problems of FATCA, Citizenship Taxation and how they incentivize Americans to renounce their U.S. citizenship

The Notice from the State Department is extraordinary. It could have described the fee reduction without more. To the credit of the Department of State, it is VERY clear that they read the approximately 910 comments submitted (mostly from individual Americans abroad).

You can read the comments here:

https://www.regulations.gov/document/DOS-2023-0026-0001/comment

 

While acknowledging they were unable to change the laws forcing Americans to renounce their citizenship, the Notice described in clear terms the relationship between FATCA, citizenship taxation and the rise in citizenship renunciations. I recommend taking the time to read the notice (at least twice) in its entirety.

Specific commentary from pages 5 – 7 included the following (note that the text did NOT include the links which I have taken the liberty of adding) …

 

Analysis of Comments:

In the 30-day period after the publication of the NPRM, the Department received a total of 910 comments, a majority of which appear to have been drawn in whole or in part from exemplars provided by various groups such as L’Association des Américains Accidentels,1 Stop Extraterritorial American Taxation (SEAT),2 and Democrats Abroad.3 The Department will address the issues raised by the commenters.

The overwhelming majority of commenters (880), including some who did not comment on the proposed fee change at all, expressed frustration with the U.S. system of worldwide taxation of its citizens and the expense associated with compliance with U.S. tax laws. Many reported spending hundreds or thousands of dollars a year on tax professionals, even when they might have no U.S. tax liabilities. Some stated that despite being required to comply with U.S. tax laws, they received and/or benefited from few of the services for which their taxes were collected – e.g., free COVID vaccines, Medicare Part B, and improved U.S. infrastructure. A few also expressed political objections to the way their tax dollars were used.

In addition to frustration with the U.S. system of worldwide taxation (referred to as “double taxation” by many commenters), commenters took particular issue with FATCA, stating it has made it difficult for them to invest in exchange-traded funds (ETFs) or mutual funds, obtain a mortgage, or open a bank account in their countries of residence. Some noted that they also faced difficulties investing in the United States, due to lack of a U.S. address and phone number. This significantly impacted their ability to save for retirement. Relatedly, commenters expressed frustration with the complicated reporting requirements imposed by FATCA as well as by Foreign Bank Account Reporting (FBAR), Passive Foreign Investment Company (PFIC), and Global Intangible Low-Taxed Income (GILTI) rules.

The Department is acutely aware of the concerns expressed by the commenters, some of which prompted the Government Accountability Office (GAO) to task an interagency engagement in its 2019 report to Congressional Committees. (See GAO 19- 180 “Foreign Asset Reporting – Actions Needed to Enhance Compliance Efforts, Eliminate Overlapping Requirements, and Mitigate Burdens on U.S. Persons Abroad,” available at https://www.gao.gov/products/gao-19-180 ). GAO tasked the Departments of Treasury and State and the Social Security Administration to “establish a formal means to collaboratively address ongoing issues that U.S. persons living abroad encounter from implementation of FATCA reporting requirements.” The Department of State engaged in good faith discussions regarding its possible contributions, and due to the coordinated efforts of the interagency, the GAO determined that the recommendation was implemented.

The Department, however, cannot alter U.S. tax compliance laws for citizens residing overseas, or otherwise address concerns related to worldwide or so called “double” taxation. The Department likewise cannot amend the user charges statute – which applies to fee collections government-wide and not just those charged by the Department of State for consular services – to exclude those without “sufficient residential connection to the United States” from the payment of the fee for CLN services, as proposed by L’Association des Américains Accidentels.

As stated in the NPRM, the proposal to lower the fee for CLN services took into account the not-insignificant anecdotal evidence regarding the difficulties that many U.S. nationals residing abroad have reported they are encountering. It is designed to help alleviate the cost burden for requesting CLN services, even though the fee of $450 reimburses only a fraction of the cost to the U.S. government of providing such services.

Here is the link to read more:

Click to access 2026-04931.pdf

A “Shout Out” to all those who took the time to comment – Your work paid off!

If individuals had not taken the time to submit comments, the State Department would never have included the discussion of FATCA and citizenship taxation in the “Notice”.

To put it simply:

The small comments of individuals Americans abroad led to a big result!!

Congratulations!

The trend is your friend

The message from the community of Americans abroad (and the various organizations) is beginning to be understood by certain branches of the U.S. government.

Examples of the beginning of understanding (from the Executive Branch) include:

– the 2019 adoption of the IRS “Relief Procedures For Former Citizens” (Treasury/IRS)

– the 2025 Taxpayer Advocate Report (Taxpayer Advocate)

– the 2026 Reduction of The CLN fee (Department Of State)

These are powerful statements and acknowledgements from the Executive Branch of Government that FATCA and citizenship taxation are serious problems.

Part C – Acknowledgements From The Executive Branch Will Help With Delivering The Message To Congress

There have been two legislative attempts to amend parts of the Internal Revenue Code to make the tax situation for Americans abroad less toxic and more tolerable. These are:

– the Holding bill introduced in 2018; and

– the LaHood bill introduced in 2024.

Notably neither bill proposed an end to citizenship taxation. That said, both proposals, if enacted would provide much needed relief to Americans abroad in general.

Although a “Simple Regulatory Fix To Citizenship Taxation” remains possible, the time has come for Congress to consider a a permanent legislative fix to citizenship taxation!

 

As Republicans Overseas points out, Congress must listen and make the changes to the law …

ACA Continues its relentless advocacy and continues to call for “Congressional Hearings”

Tax Fairness Abroad Asks Congress To Address Tax Policy Failure

Expat tax  firm cautions that it’s less costly to renounce, but citizenship taxation is alive and well until changed by Congress

 

Conclusion

Of course the reduction of the fee for a CLN from $2350 to $450 is good news. The better news is the State Department acknowledgement that renunciations are caused by U.S. tax policies that are unique (U.S. citizenship taxation is far worse than Eritrea’s version of citizenship taxation) in the world and contrary to the interests of the United States.

For many change cannot come soon enough. For others they need to renounce now.

 

John Richardson

 

Appendix:

On January 4, 2026 I published a post on Brock titled: “People Are Not Renouncing Because They Want To, They Are Renouncing Because They Have To“.

Americans Abroad Aren’t Renouncing Because They Want To. They Are Renouncing Because They Have To!

 

 

That post featured a reminder that in January of 2023 the State Department had made a promise to reduce the fee for a Certificate Of Loss Of Nationality from $2350 to $450. It is now March of 2026. The article noted that it had been three years since the pledge to reduce the fee.