Hong Kong has occasionally scared public health authorities in the United States with acronyms like SARS and H1N1, but now the U.S. is attacking the world’s financial health with a far more dangerous acronym: FATCA. The Hong Kong Economic Journal — the Financial Times of the Sinophone world, roughly speaking — ran a FATCA-related interview with Jennifer Wong of KPMG in this morning’s paper, on page A7. I’ve translated it below.
Author Archives: Eric
Yet another renunciant whose name isn't in the Federal Register. How many more are there?
Reuters ran an interesting piece on St. Kitts’ economic citizenship programme today, which inevitably touched on the issue of renunciation of U.S. citizenship. However, I was disappointed that the author missed the opportunity to fact-check the U.S. government in the following paragraph:
Adam Bilzerian, a professional poker player and the son of former corporate raider Paul Bilzerian, said he worked through Henley to get citizenship in Austria. But put off by the cost and exclusivity of Austria’s program, he purchased property in St. Kitts, filled out some paperwork, and within a year, became a Kittitian. Then, he became one of 231 Americans to renounce his U.S. passport in 2008. In 2011, government records show, the number of Americans renouncing their citizenship reached 1,788 – the highest number since the government began keeping track in 1997.
Except that Bilzerian’s name does not appear in those “government records”. Continue reading
Son of FATCA: Carl Levin’s "CUT Loopholes Act" (S.2075) will make normal business even harder for American expat entrepreneurs and all other Americans abroad
Senator Carl Levin, not yet ready to rest on his laurels with the damage he’s done to Americans abroad by sneaking FATCA into the HIRE Act at the last minute, has apparently decided it’s a good idea to decrease American economic activity by making it even harder for Americans abroad, especially expat entrepreneurs, to do business with domestic American suppliers of goods and services. The full text of his newly-proposed “CUT Exports Loopholes Act” is not yet available publicly, but he’s already put out a press release about it. In his floor statement, he described it as a subset of what he attempted to get implemented in the “Stop Tax Haven Abuse Act” (S.1346). Continue reading
Politicians all around the world discuss FATCA
Americans abroad — frustrated by the uncertainty of what FATCA will do to their financial lives, and facing repeated delays of the IRS’ promises to bring some clarity through proposed regulations — are increasingly turning to the politicians of the places where they live in an effort to get some answers. In the past week several government officials at the national or supranational level have brought up the issue of FATCA, in response to concerns expressed by constituents — both dual citizens who elected them, and banks and other institutions for whom FATCA amounts to yet another extra-territorial unfunded mandate by the US. A number of scholars have also released draft papers about FATCA and FBAR. Here’s the roundup for the past week or so. If you see any more, leave them in the comments:
How many Americans naturalise in European Union countries each year?
Along with the U.S. government-reported number of Americans who lose U.S. citizenship each year, various foreign governments report another number that might make American homelanders uncomfortable: the number of Americans who applied for naturalisation in other countries each year. Not all of them necessarily lose U.S. citizenship, but some certainly do.
1,781 Americans renounced citizenship in 2011, according to the Federal Register
The Federal Register has just published the names of 360 former Americans who renounced citizenship in the fourth quarter of 2011. This brings the total number of published renunciants for last year to 1,781, compared to 1,485 for 2010. This includes 499 from January to March, 519 from April to June, 403 from July to September, and 360 from October to December. Internal Revenue Code Section 6039G requires that “[n]otwithstanding 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.” It’s an open question whether this list is actually complete. The RenunciationGuide.com website has expressed concerns about the completeness and quality of the data. International tax lawyer Andrew Mitchel at one point concluded that this list should only contain “covered expatriates”, but later re-examined the issue and concluded that it contains the names of all former Americans who lost citizenship in the period in question.
Update: Andrew Mitchel also just put up some nice charts on his blog with the number of published renunciants by year and by quarter, going back to 2004.