# Specific questions on renouncing US citizenship



## USExpat111

Hi, I've been looking into the renunciation documents from the US embassy website and I have a few questions for people with experience/knowledge. Apologies if these have been asked/answered already, but this is quite a long thread.

1. I understand if you have net worth under $2m, you should not be a covered expatriate who has to pay any exit/income taxes apart from the £2350 fee for renouncing correct? 

2. For form 8854 Section B, what do they mean by eligible/ineligible deferred compensation items? Would deferred items include pensions when one retires in the future, and would those be eligible or ineligible? Also, what are "specified tax deferred accounts" and "non-grantor trusts"?

4. For those who have renounced, have you had any issues/problems returning to the US to visit? Have you had to go to the embassy to apply for a visa to visit the US, or what kind of visa is required, and what is the maximum time one can visit the US as a non-citizen?

5. They ask for your birth certificate as one of the required documents if you wish to renounce. What if this cannot be located/found?

6. Is form 8854 filed only the year after you renounce, along with a 1040NR, or are both forms filed every year if you have US source income? 

Thanks for any help answering these questions!


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## Bevdeforges

Have moved your post into a thread of its own, as I think the questions are important and may be of interest to many folks here.

Philosophical or political comments or debate should still go in the "sticky" thread. 
Cheers,
Bev


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## JustLurking

Not a former US citizen, but I'll offer answers to the points I do know about. Hopefully someone else will swing by soon to fill in the others.

1) Yes, provided also that your average net tax liability over five years -- not income, but _liability_ -- is below $157k (2014 figure, adjusted with inflation). There are a couple of other escape clauses too, such as being born dual or being a minor.

2) It's ugly. The exit tax can include pensions. And potentially non-US pensions, built up with non-US earnings. In the worst case, you pay US tax on your entire pension balance (or actuarial value if a defined benefit scheme) as if distributed completely on the day you renounce. Tax on _pretend_ income that must be paid with _real_ money, perhaps 40% or more on what you have saved, and destroying your chance at retirement. In the best case, you agree to pay 30% to the US when you do withdraw from your pensions, and to do that you have to waive any US treaty rights you might have (the IRS has a special form for this, the W-8CE). Here the exit tax potentially simply tramples tax treaties to which the US has previously agreed and signed, but it's not like you have any redress. Your best bet is to ensure you are not a covered expat. Give away money if necessary, to duck under the $2mm bar.

5) You only file the 8854 once, with your final year return. Although because the IRS is grossly inefficient you have to do their internal communcations for them, and send a second copy of the 8854 separately to Philadelphia. After that the US treats you just like any other NRA, at least for tax purposes. The 'annual 8854' is only for people who renounced between 2004 and 2008, when the rules were different.

Hope that helps. Good luck with the process.


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## USExpat111

Thanks, Bev and Lurker! Yes, I'm quite worried about the pensions. I think I'd be comfortably under the $2m mark, but UK property prices are so high, I do have foreign pensions expected, and the exchange rate just inflates everything. I'm just looking into renunciation, not 100% sure yet. My brain says yes, my heart and family in America say no. The filing/reporting requirements and calculations on form 8854 looking so complicated to figure out don't particularly help push me towards the renunciation route either. Still don't understand what eligible/ineligible deferred items and those other bits listed on Section B are. Anyone?


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## JustLurking

The ever-reliable Phil Hodgen has a decent description here of deferred compensation and its eligibility or otherwise. Even with Phil's best efforts at cutting through the IRS sludge, it's still a quagmire. Best synopsis is something like: if it's a 401k, IRA or other US plan it's probably eligible; if it's a non-US pension plan it's probably ineligible. Though the exit tax treatment of both is execrable, the treatment of _ineligible_ pensions is hard not to consider as outright theft.

If you are truly flirting with covered expat status, look out for section 2801. Again, stuff from Phil Hodgen here. Phil considers section 2801 to be the dumbest thing in the US tax code. I think he understates it. It may be the dumbest thing in _any_ tax code you could pick, US or otherwise.


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## BBCWatcher

JustLurking said:


> Tax on _pretend_ income that must be paid with _real_ money, perhaps 40% or more on what you have saved, and destroying your chance at retirement.


Perhaps 80%. Perhaps 95%. Perhaps 200%. Those figures are _mathematically_ possible....

Now let's explain how it works, shall we? (And no, as you'll see, "destroying your chance at retirement" is most probably hyperbole. Let's just stick to the facts then let adults decide for themselves what to make of it. We have enough politics here.) If you're subject to the Expatriation Tax then you value your worldwide assets using a mark to market approach, and you calculate the net gains. You subtract the exclusion from the gains ($680,000 in tax year 2014) -- the first large portion of your mark to market gains are tax exempt -- and the remainder is taxed at regular capital gains tax rates (and the U.S. cost basis is then reset). (The cost basis reset is important especially for U.S. source assets.)

So, hypothetically, if you're in the wonderful, enviable position of having saved $1,000,000 that then grew into $10,000,000 (a ten fold increase in wealth) -- and let's suppose that $10 million represents your total assets -- then your mark to market gain is $9 million. Subtract $680,000, and you get $8.32 million. Let's assume none of those gains have been previously taxed by anyone. Tax that $8.32 million at a 20% net effective capital gains tax rate (for example) and that's $1.664 million in Expatriation Tax owed. In this example that's 166.4% of what you saved ($1.664 million versus $1 million), mathematically speaking.

Which is of course how capital gains taxes work practically everywhere. So there's not actually any useful meaning in that particular percentage. The tax rate versus what you saved can be practically anything since gains can be practically unlimited depending on how lucky you were/are. But, now you (and other readers) are better informed as to how this Expatriation Tax works, and you can decide what its implications are in your personal circumstances.

Note that it may be possible to take a (valid) treaty position on an Expatriation Tax -- I'm not sure about that. I'm not aware of a specific restriction on that particular combination. Also, a foreign tax code may (or may not) deem Expatriation Tax to be a creditable foreign tax in their tax system. And, as mentioned, the cost basis is reset which becomes relevant if any assets are subject to future U.S. tax. So those factors differ depending on individual circumstances.


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## USExpat111

That Hodgen link was very helpful, thank you Lurker! Thank you too for your explanation, BBC, that was also very interesting and helpful, especially about the $680k exclusion.


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## JustLurking

BBCWatcher said:


> ...Now let's explain how it works, shall we? (And no, as you'll see, "destroying your chance at retirement" is most probably hyperbole. Let's just stick to the facts then let adults decide for themselves what to make of it.


Yes, let's.

Your example entirely ignores pensions, presumably because you did not research the issue sufficiently. Retirement savings are _not included_ the mark-to-market part of the exit tax, and not covered by the $680k exclusion. For retirement savings, the exit tax says you have to add the entire balance to your income for the final year as if distributed, even though it was not. See section 5 of IRS notice 2009-85 and IRC section 877A(d)(2)(A).

Here is an example that is many times more likely to occur than your own. After 40 years of working you own a $1m home which you bought for $500k, and have saved $1m in non-US retirement accounts. This is a long way from beyond dreams of avarice. Middle class home in a middle class neighbourhood, and less than middle class income drawable from retirement savings.

Under the mark to market part of US exit tax you have nothing to pay on the $500k increase in your home's value. Under the deferred compensation rules, you have to add $1m to your income for your final year. That gives an instant US tax liability of $374k, and reduces the amount you can live on for the remainder of your retirement by nearly 40%, taking you from beer and pretzels to catfood and water.

_That_ is retirement destroying. It visibly applies to folk who are far, _far_ away from the "billionaires and multi-billionaires" that congress demagogued when justifying the exit tax to itself. And now you (and other readers) are better informed about how the exit tax ravages retirement savings.



BBCWatcher said:


> Note that it may be possible to take a (valid) treaty position on an Expatriation Tax...


Grey area. Perhaps, but so far nobody has attempted this. The results will be interesting. There is no relief for people in non-treaty countries, though.


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## theOAP

JustLurking said:


> Here is an example that is many times more likely to occur than your own. After 40 years of working you own a $1m home which you bought for $500k,.....
> 
> ......Under the mark to market part of US exit tax you have nothing to pay on the $500k increase in your home's value.


May I enquire how you arrive at this conclusion? Is it due to the fact when filing your final 1040 you will be paying gains on the increase?


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## JustLurking

theOAP said:


> May I enquire how you arrive at this conclusion?


Because the $500k gain falls within the $680k mark-to-market exclusion (and assuming no other capital gains elsewhere take you over).


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## theOAP

JustLurking said:


> Because the $500k gain falls within the $680k mark-to-market exclusion (and assuming no other capital gains elsewhere take you over).


OK, I understand you're thinking.

May I alter your figures slightly. At "deemed sale", a home has a value of $1,000,000; a basis of $400,000; and a gain of $600,000, which is also highly believable for a property purchased 20 years ago in the UK. It's my understanding normal "sale" rules apply for the exit tax, and for the UK there are two possible outcomes. If the property was held as Joint Tenants (beneficial joint tenants), the basis is $400,000 and the gain is $600,000. For Tenants in common (shares at say 50/50), the basis is $200,000 and the gain is $300,000. Of course we also have the games of exchange rate variations between purchase and deemed sale. There seems to be no allowance (exempted amounts of $250,000/$500,000) under the exit tax rules. Hodgen is also somewhat speculative on this.

Pensions are a bit more confusing. It's clear for US eligible pensions, but unclear for foreign pensions. In fact, the instructions for 8854 are woefully poor. The lines concerning both foreign properties and foreign pensions have, in fact,.... no instructions. How is a pension already in drawdown stage calculated. Should it be calculated at all (is it still an asset)? Even Hodgen refuses to be drawn on the question of State Pensions (foreign social security). Are they included? They're not included on 8938, but 8938 has nothing to do with the exit tax.

The IRS seems unconcerned on the varification of figures for Part V, Sch. A, but of course those figures need to be accurate if one wants to avoid being a covered expatriot by completing a final 1040 with accurate figures.

There are some excellent professionally prepared final 8854 and 1040 (all forms) using 5 hypothetical scenarios on the citizenshipsolutions dot ca website, but I'm not sure if we're allowed to link from this site. If anyone is interested, send me a PM and I'll send the link.


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## BBCWatcher

I agree substantially with theOAP about defined contribution pensions, which is what we're talking about here.

I'd also point out that real estate gains are calculated net of allowable costs, and there are many, many allowable costs. You don't just subtract buying price from selling price unless you're flipping property (very successfully) or you're something like (or actually) a slum landlord. That's just not how IRS gains are calculated for most real estate.

Yes, I suppose we could all dream of worst case scenarios, but there are also best case scenarios and various scenarios in between. Like every tax system on the planet that I've ever encountered, tax impacts are situational and vary according to individual circumstances. They're rarely worst case or best case. And we're already discussing a very unusual tax situation, a tax situation that some _hundreds_ of individuals choose to face per annum. (Among the couple thousand U.S. renunciants per year, it's quite reasonable to predict that most don't owe a dime in Expatriation Tax. The Expatriation Tax is purely a voluntary tax by definition and is, presumably, rationally chosen -- we would hope anyway.)


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## theOAP

BBCWatcher said:


> I'd also point out that real estate gains are calculated net of allowable costs, and there are many, many allowable costs. You don't just subtract buying price from selling price......


Could you point out where exactly in the exit tax information these are allowed? This is not a normal sale process with a sales completion. This is a deemed sale, and most references indicate that under the exit tax procedure, normal rules do not apply.


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## JustLurking

BBCWatcher said:


> ...And we're already discussing a very unusual tax situation, a tax situation that some _hundreds_ of individuals choose to face per annum.


An admission that this is a dreadful outcome, but minimized by the claim that it is niche. A bad law that only affects a few people is still a bad law.

The exit tax issue with respect to pensions for _my situation_ was sufficiently awful that it prompted an earlier departure than planned from the US, and my refusal to take US citizenship even though eligible before leaving. A substantial net _loss_ to the US in tax from me, then, because of the exit tax.

I will not be alone in this. What the exit tax asset limit does, more than anything, is prompt one to expatriate _early_ rather than later or not at all, to avoid breaching the limit as (unrealized) capital gains accrue, inheritances arrive, and so on. And it prompts green card holders to leave the US before eight years is up. Your belief that most expats don't owe the exit tax is probably correct, but largely because its presence acts as a motivating function for them to go early and before it applies.

The pensions example I gave is not "worst case". It is much closer to the normal case than you appear willing to accept.



TheOAP said:


> Pensions are a bit more confusing. It's clear for US eligible pensions, but unclear for foreign pensions. In fact, the instructions for 8854 are woefully poor.


The 8854 instructions say nothing about non-US pensions, but IRC section 877A(d)(4)(B) clearly includes them:


> For purposes of this subsection, the term “deferred compensation item” means—
> ...
> (B)any interest in a foreign pension plan or similar retirement arrangement or program,


The general consensus is that SS and state pensions are excluded. Defined contribution and (worse) defined benefits appear to be in scope, though. At least one UK tax planner views the US exit tax as a double-taxing treaty override.


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## BBCWatcher

theOAP said:


> Could you point out where exactly in the exit tax information these are allowed? This is not a normal sale process with a sales completion. This is a deemed sale, and most references indicate that under the exit tax procedure, normal rules do not apply.


Yes, it's a mark to market deemed sale, but IRC Section 877A uses the terms "gain" and "loss" specifically. Those terms are not separately defined in Section 877A as far as I can tell. Given ordinary, common statutory and regulatory interpretation, you have to give every word _some_ meaning, some weight, and the only available meaning for "gain" and "loss" is elsewhere in the tax code. So whether it's a deemed sale or an actual sale, one would have to calculate the gain (or loss) on real estate according to...how to calculate the gain (or loss) on real estate.

_Unless Section 877A says otherwise_, but it doesn't as far as I can tell.

I don't think I'm making a controversial assertion here at all. The burden would be to find something in the expatriation provisions (specifically) that says "gain" and "loss" aren't calculated as elsewhere in the tax code. I just don't see that, so the ordinary definitions must apply here -- I don't see any other viable interpretation.


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## theOAP

BBCWatcher said:


> Yes, it's a mark to market deemed sale, but IRC Section 877A uses the terms "gain" and "loss" specifically.


I agree with your comments in general. In MtM, there's a basis, a final value, and a gain/loss. Adjustments normally can be made for "costs". In this case, we're looking to Sec. 121 cost allowances. These include the exemptions allowed ($250,000/$500,000). The sticky bit is the uncertainty by professionals such as Hodgen relating to the normal 250/500 exemption. I thought the exemption was contained in Sec. 121. If the pros are uncertain to the exemption allowance, then certainly all other allowances in Sec. 121 must also come under suspicion. And from all the comments, they _are_ uncertain.

Again, the exit tax considers the value of assets as they exist the day prior to renunciation. (What new light fittings?  )


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## BBCWatcher

JustLurking said:


> An admission that this is a dreadful outcome....


Ah, no. This is a tax rate of ~20% (usually less on a net effective basis), voluntarily chosen, levied on multimillionaires. In a ranked list of "dreadful" tax code provisions, the vast majority of Americans wouldn't actually rank this one on the list. It'd be #1381 on the top 100 list -- something like that.



> A bad law that only affects a few people is still a bad law.


"Bad" in what sense? That's the funny, "odd" thing about tax laws (and regulations): they raise "good" revenue.

Which is not to say that I like paying taxes. Not at all! But I must confess I do like at least a few of goods and services taxes buy. So are taxes good or bad? Yes. 

One would hope the only people paying Expatriation Tax are those who rationally choose that option because it's their lowest cost, preferred option in their particular circumstances. They're then paying very good (to the government...and to the public it serves) tax revenues that then go and fund the U.S. National Cancer Institute's research programs, to pick a random example.



> The exit tax issue with respect to pensions for _my situation_ was sufficiently awful that it prompted an earlier departure than planned from the US, and my refusal to take US citizenship even though eligible before leaving. A substantial net _loss_ to the US in tax from me, then, because of the exit tax.


Well maybe -- let's just assume you are correct in your individual circumstances, and I trust you know your own counterfactuals. But "so what"? It'd be very surprising indeed if any tax system were so cleverly designed that every individual always acted in government revenue-maximizing ways at every opportunity. (Note also by the way you cannot substantially benefit from U.S. government-provided services. The deal cuts both ways. You may have exited, but you also aren't going to be able to land indigent in a U.S. nursing home for example -- not very easily, anyway.)

"Be careful what you wish for," by the way. There are many very careful, rigorous academic studies that strongly suggest top marginal income tax rates for revenue maximization with tolerable (or less) economic distortions can be on the order of 70%. As they used to be in the United States (and elsewhere). In fact, the U.S. used to have a top marginal federal income tax rate of 91%.



> I will not be alone in this. What the exit tax asset limit does, more than anything, is prompt one to expatriate _early_ rather than later or not at all, to avoid breaching the limit as (unrealized) capital gains accrue, inheritances arrive, and so on. And it prompts green card holders to leave the US before eight years is up.


Well OK, but at most it encourages a couple thousand individuals to act as such per year because that's the total universe -- and a few hundred is a more realistic figure. (I don't actually believe that most renunciants renounce for tax reasons. There are many, many reasons why people renounce their citizenships.) It probably also encourages a far greater number of individuals to act in some other ways. I'll trade counterfactuals with you: the existence of the Expatriation Tax tends to discourage me from becoming one of those couple thousand individuals. (Other things do as well -- much more so -- but rationally, dispassionately, it is a bit of a brake added on top of others.)



> Your belief that most expats don't owe the exit tax is probably correct, but largely because its presence acts as a motivating function for them to go early and before it applies.


Not many are going at all, though, as I mentioned. And nearly one million are coming into full citizenship every year. If I were running a business with a couple thousand customers leaving but nearly one million new customers every year, that'd be a pretty damn impressive business, I'd say. Apple cannot even claim those sort of relative figures, and they do pretty well in iPhone customer retention, for example. But every year, every month, every day they lose a few customers. And thank goodness they _can_ (and do) lose customers, because that means smartphone customers have choices. So do U.S. citizens, thank goodness -- there are actually a couple hundred citizenships in the world.


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## newthilde

JustLurking said:


> 5) You only file the 8854 once, with your final year return. Although because the IRS is grossly inefficient you have to do their internal communcations for them, and send a second copy of the 8854 separately to Philadelphia. After that the US treats you just like any other NRA, at least for tax purposes. The 'annual 8854' is only for people who renounced between 2004 and 2008, when the rules were different.
> 
> Hope that helps. Good luck with the process.


Interesting - I didn't realize that the annual form is no longer required. Where can I find the provision for this (Code or Regulations)? Does anybody here have experience with filing this form? (This doesn't affect me personally but I have been curious about this particular provision and the entire ex-patriation process for a long time.)


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## JustLurking

BBCWatcher said:


> "Bad" in what sense? That's the funny, "odd" thing about tax laws (and regulations): they raise "good" revenue.


Bad in the sense that this one probably _reduces_, rather than increases revenue.

At the margins it causes people to exit the US tax system earlier than they might otherwise have or perhaps where they would not have at all. A few years ago there was no exit tax, but now people see the door closing and may wish to go through it before it slams shut.

It also causes (uncounted) numbers of people to avoid immigrating to the US in the first place. The US exit tax sends a strong message to would-be immigrants that the US is hostile towards departures. Globally mobile employees consider not only the prospect of moving into a country, but also their possible later departure.

In practice it may well be that few people pay it. But the behavioural changes that result from it have costs that likely outweigh anything it raises. The exit tax probably more than destroys the revenue stream it was intended to tap.



BBCWatcher said:


> ... tax revenues that then go and fund the U.S. National Cancer Institute's research programs, to pick a random example.


Your use of the word "random" is deliberately misleading. According to a 2013 article from Forbes the US spends 28 times more on defence as on cancer research. It is revealing that you chose the much less likely example.



BBCWatcher said:


> ...at most it encourages a couple thousand individuals to act as such per year because that's the total universe -- and a few hundred is a more realistic figure.


It's been pointed out many times to you that this figure is understated. And consider the universe of globally mobile, successful and well educated professionals who reject moving to the US in favour of Canada, Europe, Australia and similar because of the US exit tax and other unwelcome US tax drawbacks.


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## USExpat111

I am tending to agree with Lurker that the exit tax is a great motivator to renounce earlier when one might have less things to worry about like accruing capital gains, pension payouts, and inheritances. However, on the flip side, if a person remains a US citizen abroad and one day has to pay US taxes on their foreign pensions and inheritances from US persons, how bad is that? I suppose one can't use the FEIE on pension income? If a person received inheritance from a US person, wouldn't the beneficiary have to pay inheritances taxes to the US even if they weren't American no matter whether they lived in the US or abroad?


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## Bevdeforges

It's not the beneficiary of the estate who pays the inheritance taxes. It's the estate itself before the estate is distributed. (Federal inheritance taxes, at least.)

On the foreign (government) pensions, it depends on the terms of the relevant tax treaty between the US and whatever country the overseas taxpayer is resident in. And there are a couple of interesting variations - many places, the country that is the source of the pension is where you pay the tax. But there are a few places where, for example, US Social Security pensions are taxed only by the country of residence of the taxpayer per the treaty.
Cheers,
Bev


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## JustLurking

USExpat111 said:


> ... if a person remains a US citizen abroad and one day has to pay US taxes on their foreign pensions ..., how bad is that? I suppose one can't use the FEIE on pension income?


On pensions, you'd be reliant on the FTC to shield you from US tax on pension withdrawals.

If you remain in the UK this is probably a reasonable bet. US federal tax rates at the margins are generally considered to be lower than UK rates. Whether they will remain so in future is unknown, but I would think it likely.

If you moved to Portugal the story might be different. Portugal currently offers a 10-year income tax exemption for foreign retirees, so there you would have nothing against which to offset your US tax liability on pension income. A non-US citizen doing the same would keep much more of their money than you would.

Your larger problems arise generally from things like inability to use an ISA as a tax shelter, difficulty in using cheap index funds for investments, inability to sell your main home without any capital gains tax no matter how much you sell it for, and tax traps from all the other areas in which the US and UK tax systems don't match up. And post-FATCA, that UK investment platforms such as Alliance Trust and Interactive Investor now refuse accounts for US citizens outright, even ones who are dual and live in the UK.

Some of these have a real expense associated with them. Others can perhaps be worked round to an extent. Only you can decide whether keeping your citizenship is a worthwhile tradeoff for the drawbacks.



USExpat111 said:


> If a person received inheritance from a US person, wouldn't the beneficiary have to pay inheritances taxes to the US even if they weren't American no matter whether they lived in the US or abroad?


Right. The US estate tax is paid by the decedent's estate, so (except for section 2801) the recipient never has a tax liability from a gift or bequest. No likely issue there then, though you want to watch out for section 2801 if you yourself become a 'covered expatriate' by renouncing.


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## BBCWatcher

There's a discussion here of behaviors that tax policies encourage or discourage. Yes, tax policies do that, but there are many competing factors in this particular set of tax policies. I don't think there's any credible evidence that particular factors outweigh others in this case. Indeed, there's circumstantial evidence that these particular policies motivate very, very few people -- yes, genuinely, on the order of hundreds (a subset of renunciants) to act in ways contrary to U.S. government revenue raising -- and, more importantly, measured as revenues less costs, as I pointed out -- versus a hypothetical alternative policy.

At most there's a hypothesis in this thread that the current policy could be improved from a government revenue-minus-burden point of view. OK, so the Congressional Budget Office (for example) could score that hypothesis.

And, as I mentioned, "be careful what you wish for." It's at least as likely that CBO could determine that the current Expatriation Tax policy (and rate) is set too _low_, that it ought to be tightened in order to raise greater net revenues for the Treasury. There's absolutely nothing set in stone about the $680,000 (2014 tax year) Expatriation Tax exemption, for example -- or any other provision.


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## USExpat111

Is that $680k exclusion for everyone or just married persons?


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## jbr439

BBCWatcher said:


> I agree substantially with theOAP about defined contribution pensions, which is what we're talking about here.
> ...


Well, defined benefit pensions also suffer a similar fate as their present value is used in determining their worth. So one can end up, as stated before, owing real taxes on assets one is not in possession of (and may never be in possession depending on longevity and the terms of the pension). Nice deal for the USG, sucks for the covered expat.


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## JustLurking

USExpat111 said:


> Is that $680k exclusion for everyone or just married persons?


Per individual.

Your final year US return will be a 'dual status' one, and unless you elect to be taxed as a US citizen for the complete year it cannot be a joint return.


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## BBCWatcher

I found the 2015 tax year exclusion figure: $690,000. Every year that figure is adjusted for inflation.


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## JustLurking

BBCWatcher said:


> I found the 2015 tax year exclusion figure: $690,000. Every year that figure is adjusted for inflation.


The asset limit set in 2008 remains unadjusted for inflation. If it had been it would now be $2.3m.


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## USExpat111

Thank you, everyone. The requirement of having to calculate net worth for Form 8854 are themselves offputting to renunciation, as I suppose it is supposed to do. Several of you are now discussing determining PV of a pension. I'm not even sure what kind of pensions I have, ie if they are DC or what. I thought one could just use the transfer value stated on recent pension statements for the FMV, which is what I usually use for the FBAR forms. Is that not the case? Do pensions have a cost basis? For properties, isn't the FMV of a property really just what one would expect it to sell for on the present market? Does one need paperwork to back up FMV property estimates?

These kind of complex rules and calculations for IRS forms are both what drive me to want to renounce and now put me off from doing it, sigh. I'm certainly not poor at math, but it really isn't reasonable that the IRS should expect average middle income US citizens to spend so many precious hours, days, and in my case, usually months of their lives trying to work out complicated and confusing accountancy rules and calculations. Perhaps some people really enjoy doing this kind of thing and have the time, mentality, and patience to work out all these rules and forms. Personally, I just want to cry every time I see an IRS form or rule I haven't seen or dealt with before, as it likely means weeks or months of gathering statements and working out how to fill the forms in.


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## JustLurking

USExpat111 said:


> ... Do pensions have a cost basis? For properties, isn't the FMV of a property really just what one would expect it to sell for on the present market? Does one need paperwork to back up FMV property estimates?


Here is what I would do.

If well under the $2mm asset limit and other exit tax tests, just use the best figures you have to hand for the 8854. If the IRS challenges them, _that_ is the time to get appraisals, official valuations, and so on. Ultimately this might change the 8854 numbers slightly, but provided you are comfortably under the $2mm it won't matter. There's nothing at all to pay until you hit that magic number, so provided you're short of it, perhaps with some contingency, a miss is as good as a mile.

If really close but still under, then either get some (semi-official?) appraisals and valuations now, and keep them in reserve just in case the IRS requires backup documentation. Better still, do what you can to reduce your assets so they are more comfortably under. Gifts to spouse may be a good way.

If over, then again see if you can scrape under by giving stuff away. Even if this means a gift tax return it will be worth the effort.

If over and you simply cannot reduce your assets to be under in any way, your options narrow considerably. Either don't renounce but just suck it up, leaving you with a possible US estate tax risk. Or reorganize as best you can to mitigate the exit tax, then renounce and again suck it up. This is the unfortunate reality of the financial Berlin wall that the US has built over the past decade and a half.

The exit tax discourages expatriation because that is precisely what congress intended. The JCT paid lip-service to fairness with talk of making expatriation "tax neutral", but that is not what they implemented in the end. It is instructive to note that Charles Rangel, congress's primary architect of the exit tax, is himself a confirmed tax cheat.



USExpat111 said:


> Personally, I just want to cry every time I see an IRS form or rule I haven't seen or dealt with before, as it likely means weeks or months of gathering statements and working out how to fill the forms in.


I sympathize, because I know that feeling far too well.

I am certain that for many it is _this_, rather than the actual tax dollars paid (if any), that has driven the renunciation numbers to several multiples of what they were before FATCA. What I can also say, from direct experience, is that the relief of getting out from under it is tremendous.


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## theOAP

JustLurking said:


> If well under the $2mm asset limit and other exit tax tests, just use the best figures you have to hand for the 8854. If the IRS challenges them, _that_ is the time to get appraisals, official valuations, and so on. Ultimately this might change the 8854 numbers slightly, but provided you are comfortably under the $2mm it won't matter. There's nothing at all to pay until you hit that magic number, so provided you're short of it, perhaps with some contingency, a miss is as good as a mile.
> 
> If really close but still under, then either get some (semi-official?) appraisals and valuations now, and keep them in reserve just in case the IRS requires backup documentation. Better still, do what you can to reduce your assets so they are more comfortably under. Gifts to spouse may be a good way.
> 
> If over, then again see if you can scrape under by giving stuff away. Even if this means a gift tax return it will be worth the effort.
> 
> If over and you simply cannot reduce your assets to be under in any way, your options narrow considerably. Either don't renounce but just suck it up, leaving you with a possible US estate tax risk. Or reorganize as best you can to mitigate the exit tax, then renounce and again suck it up.


+1

My sentiments exactly.


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## theOAP

Without pointing fingers:

_“….a couple thousand individuals… act [renounce] as such per year because that's the total universe -- and a few hundred is a more realistic figure. Not many are going at all….”_

It’s always (surprising, entertaining, sad; make your own choice of words) that 3,400 individuals renouncing citizenship are often viewed as a small, insignificant, piffling amount not worthy of concern, yet an equally small number (is 2,000 enough?) of undeclared accounts in a Swiss bank gives rise to a national abomination with Senators displaying dismay; Congress enacting new laws to stem the outrageous number of tax cheats; Presidential Executive Orders being issued; and the Department of Justice riding roughshod over entire banking systems.

One might speculate it’s obviously the amount of money involved. Those renouncing citizenship surely should have those foreign earned Euros/Pounds/etc. examined, and even though the 3,400 renouncers won’t generate a large amount of revenue when leaving, they’re lumped with the 2,000 undeclared or the greedy rich attempting to flee with their billions, thus no longer denying the Treasury its rightful “trillions of dollars”. Sadly, the US Congress seems unable to identify or distinguish the critical, most important factor when observing US citizens renouncing. Is it really about the money, or myopic Congressional attitudes resulting in unpleasant experiences on the individual abroad?

Spain may have its “Article 95”; Canada may have its “departure tax”; but they lack the vitriol of the US exit tax.


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## USExpat111

Hear, hear! Thank you, Lurker and OAP!


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## BBCWatcher

theOAP said:


> It’s always (surprising, entertaining, sad; make your own choice of words) that 3,400 individuals renouncing citizenship are often viewed as a small, insignificant, piffling amount not worthy of concern....


If ~3,000 individuals were renouncing Monégasque citizenship (for example), that would not be small or insignificant.

Obviously renunciation is "worthy of concern" to U.S. policymakers, to some extent anyway. Otherwise IRC 877/877A (the Expatriation Tax) and IRS Form 8854 wouldn't exist.

U.S. policymakers do occasionally worry about small numbers of individuals, or even a single individual.



> ....yet an equally small number (is 2,000 enough?) of undeclared accounts in a Swiss bank gives rise to a national abomination with Senators displaying dismay; Congress enacting new laws to stem the outrageous number of tax cheats; Presidential Executive Orders being issued; and the Department of Justice riding roughshod over entire banking systems.


No, the number is not "equally small" -- not even close to equally small. It's much larger in two ways: the number of Americans with undeclared overseas accounts, and (more importantly for policy) the tax revenue losses associated with those undeclared accounts.

Just to give you one, small data point, within just the past few years of the IRS's voluntary compliance programs, at least 50,000 Americans have asked for amnesty -- over 10,000 per year, it would appear. At last report those 50,000 Americans have poured $7 billion into the U.S. Treasury.

Keep in mind that, contrary to this forum's perceptions, lots of Americans renouncing U.S. citizenship are not doing so for tax reasons, even as a secondary consideration. How do we know that? Well, one way we know that is that (at least on a per capita basis) U.S. renunciations were higher during the Vietnam War era. They were lower when the Foreign Earned Income Exclusion didn't exist (late 1970s), as another example. Many ex-Americans claim they're not renouncing for tax reasons and (surprise!) I believe many of them.

Americans renounce their citizenship for all sorts of reasons. There are some renouncing because the United States elected an African-American president and the U.S. is no longer going to be a majority white country (soon). A few people don't like that, so they're going some place whiter and ending their association with that progressively less white country. I haven't described the majority of renunciants by any means, but I've described a few.

Roger Ver renounced primarily because he didn't like the fact the U.S. government threw him in prison for selling explosives on eBay out of his apartment, and he'd really prefer to pursue his various business interests (Bitcoin, in particular) without regulatory or legal oversight. He doesn't think he renounced for tax reasons, and (on that point) I believe him.

I don't think it's fair to lump all renunciants into one category of motivation.



> One might speculate it’s obviously the amount of money involved.


I don't think speculation is required. 



> ....they’re lumped with the 2,000 undeclared or the greedy rich attempting to flee with their billions, thus no longer denying the Treasury its rightful “trillions of dollars”.


Sadly, it's not 2,000. You have to add at least a couple zeroes to that figure. The IRS estimates that approximately 15% of U.S. income tax legally owed isn't paid, and a substantial fraction of that involves hidden overseas assets. It's been quite surprising, even to the IRS, how many individuals have been hiding assets to evade tax. (And much of it could realistically be paid. The Swiss, ironically, have a higher rate of voluntary tax compliance.)

I should add that U.S. policymakers are also concerned about financing of terrorism, drug-related money laundering (especially in northern Mexico), and other negative aspects of undeclared overseas accounts. The Bank Secrecy Act of 1970 (that introduced FBARs) was, in large part, prompted by Mafia-fighting concerns.


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## maz57

BBCWatcher said:


> Keep in mind that, contrary to this forum's perceptions, lots of Americans renouncing U.S. citizenship are not doing so for tax reasons, even as a secondary consideration. How do we know that? Well, one way we know that is that (at least on a per capita basis) U.S. renunciations were higher during the Vietnam War era. They were lower when the Foreign Earned Income Exclusion didn't exist (late 1970s), as another example. Many ex-Americans claim they're not renouncing for tax reasons and (surprise!) I believe many of them.
> 
> Americans renounce their citizenship for all sorts of reasons. There are some renouncing because the United States elected an African-American president and the U.S. is no longer going to be a majority white country (soon). A few people don't like that, so they're going some place whiter and ending their association with that progressively less white country. I haven't described the majority of renunciants by any means, but I've described a few.


What do you know...something we can agree on. The Americans I know personally who have renounced their citizenship certainly didn't do it for tax reasons, at least not for the tax they owed because most didn't owe anything. They renounced it for REPORTING reasons. Honest people trying to do the right thing but finally realizing that its simply not possible. Also not wanting to endure this unending madness for the rest of their lives. There is also a considerable number of people I know personally who have simply chosen to ignore the whole business. Whether this will eventually cause them problems, who knows? People going this route have, in effect, unofficially renounced their US citizenship and keep it a secret known only to their close friends.

The conflict between tax codes, the unpredictable risk to their retirement savings, the default US assumption that every foreign account is evidence of tax evasion, the attack on mundane Canadian mutual funds, the attack on Canadian tax-advantaged accounts intended to assist the young and the disabled, banking problems caused by the implementation of FATCA, and the general realization that this situation will continue to get worse before it starts to get better, in short the total betrayal by their former country.....all these reasons played into their decision to shed US citizenship. In Phil Hodgen's words, they decided to "get out now, while the getting is still semi-good".

And what does choosing to remain a US taxpayer do for an expat? Nothing but guarantee the right of return, something which is of no value to those who have left and will never go back because their entire life is now in their adopted country. There is certainly no other advantage to having US citizenship for a permanent expat, but there is massive downside.

The former Americans I know rejoiced when Obama was first elected; now they detest him for what he and his administration have done to expats in the last 7 years. Today the US news is all about the Supreme Court decision upholding Obamacare; the pundits claim it will be part of Obama's legacy. (To a Canadian it sure seems like doing it the hard way, but the guy had to work with the system he had.) What I and the people I know will remember him for is the totally unjustified attack on the millions of innocent expats scattered across the globe, forcing many to make a very painful decision to protect their savings and their families. Tragic, really. And so totally unnecessary; it has accomplished nothing.


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## BBCWatcher

maz57 said:


> They renounced it for REPORTING reasons.


Some yes, many no. The reason I can confidently say "many no" is that renunciation isn't always (or even particularly often) effective in reducing paperwork. U.S. financial ties still often mean U.S. paperwork, lots of renunciants maintain U.S. financial ties and/or will have future U.S. financial ties (e.g. U.S. Social Security), and lots of renunciants are fully aware of those ongoing paperwork requirements.

There is a huge variety of reasons why the relatively few people who do terminate their citizenships do so. I do not presume to know them all or characterize them absent hard data, and we simply don't have hard data to understand all the motivations and their frequencies.


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## JustLurking

BBCWatcher said:


> ... The reason I can confidently say "many no" is that renunciation isn't always (or even particularly often) effective in reducing paperwork. U.S. financial ties still often mean U.S. paperwork, lots of renunciants maintain U.S. financial ties and/or will have future U.S. financial ties (e.g. U.S. Social Security), and lots of renunciants are fully aware of those ongoing paperwork requirements.


For people with minimal connections to the US beyond place of birth or parentage, renunciation is _extremely_ effective in reducing US paperwork. For others, while renunciation won't cure all paperwork ills, it will certainly cull the worst of them. It seems probable that _exactly_ this type of person is now most represented in the annually increasing count of renunciants.



BBCWatcher said:


> I do not presume to know them all or characterize them absent hard data ...


Absent that data, how can you feel confident enough to assert above that many do not renounce for REPORTING reasons?

In any event, reliable data cannot be obtained. DS-4079 doesn't ask for a reason for renouncing. One could add voluntary "additional information", but why waste the effort and paper? The I-407 green card surrender form _does_ ask for your reason, question 6(a), but because of the Reed amendment nobody writes "oppressive tax regime" when "moving back to country of birth" will do just as well.

This dearth of information is not just a problem for speculators such as ourselves, but also for the US govt, which now can only speculate just as we do over why the count of renunciants has increased exponentially. The increase started with FATCA, but correlation is not causation. Perhaps it is related to an increase in butter production in Bangladesh.


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## BBCWatcher

JustLurking said:


> Absent that data, how can you feel confident enough to assert above that many do not renounce for REPORTING reasons?


Many individuals renounced U.S. citizenship annually before the 1970 Bank Secrecy Act and before the 2010 Hiring Incentives to Restore Employment Act (which includes FATCA), the two laws that introduced non-tax individual financial reporting requirements ("FBAR" and "FATCA"). It is thus a _reasonable_, logical assumption that many individuals among those renouncing U.S. citizenship do so for reasons other than these two laws.

Note that the word "many" is not the word "most." "Many" does not necessarily imply "most" -- or even a majority or plurality. You may be over-interpreting a particular word. Note also this is not "many" in an absolute sense. It's some non-trivial fraction within a small cohort.


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## shidareume

Of course, one could simply ask people why they are motivated to renounce.

Why looky here, someone has done just that:


> This University of Kent survey the first academic study of its kind, and the largest look at the attitudes of Americans living abroad on this topic to date shows that income is not the key motivating factor in prompting renunciations, but that increasing reporting requirements, fears of "draconian" penalties and increasing inability to hold a bank account are factors prompting renunciation.


https://www.kent.ac.uk/brussels/studying/research/news/?view=1973

http://www.kent.ac.uk/brussels/documents/kvksurveyresults.pdf


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## theOAP

BBCWatcher said:


> Obviously renunciation is "worthy of concern" to U.S. policymakers, to some extent anyway. Otherwise IRC 877/877A (the Expatriation Tax) and IRS Form 8854 wouldn't exist.


We do agree on one point. The overriding concern of Congress is the collection of highest possible tax revenues wherever it deems possible. The last concern of Congress is the reasons for the 10 fold increase in relinquishments (including renunciations). No other comment is necessary.


Back to s877A:

If there is any confusion in this thread, it seems to come from the difference in calculating gross assets for the initial decision of being under or over the threshold for “covered expatriot” status. There then follows the actual calculations for determining net taxable assets and gains once (if) the threshold is crossed.

The balance sheet in Part V of 8854 can be used as a quick assessment of asset value for the initial look, using “column a”. You will likely use the total from “column a” on line 2 of Part IV. The question is should those figures in “column a” be gross value of assets as of the day prior to relinquishment (similar to the gross valuing of an estate as indicated in the instructions) and devoid of any Code adjustments to final taxable value (the further columns consider this). In other words, should tax calculations be considered or is it strictly the gross value bearing in mind there is provision at the bottom of “column a” to net the figures in terms of outstanding debt obligations (mortgages, for example). There is a possibility the initial estimate could result in a total above $2M, whilst the actual calculations on the tax returns results in a net valuation of less than $2M for tax purposes, but it’s too late, the individual is a “covered expatriot” and subject to the impositions this entails (providing inheritance to someone resident in the States for example, or the attempts to restrict future travel to the US).

Cash, including bank accounts, are included in the calculations for “column a” so it becomes a part of the final assets value in determining if you are above the threshold, yet on the final tax return, the only declarable amount is the interest paid in the year up to the date of relinquishment. A savings account of $300,000 (you avoid any PFIC complications) may tip the balance.

The treatment of IRA’s and government pensions held in the States is complicated since (IMHO) under 877A any Treaty provisions applying to a non-resident or citizen of another country resident in that country are void.

Which brings about the question of a basis in either a ROTH held in the States or any foreign pension. For a foreign pension, it is likely the individual will have some basis in the pension, or possibly, a 100% basis if all contributions and increases have been declared prior on past 1040 returns. What figure is used for the initial value of assets for determining above or below the threshold. On the day prior to relinquishment, the asset value is the full value of the pension. 

What does seem obvious is that any total of assets worth more than $690,000 (? 2015) demands careful scrutiny, and as much as I hate to say it, for any figure approaching $2M it may be wise to consult a professional competent in the exit tax. It would be foolish to think TurboTax will sort all this out (unless, of course, you’re Tim Geithner).

Anyone, please feel free to correct me anywhere I’m wrong, which I well could be.


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## HillbillyCanuck

USExpat111 said:


> 4. For those who have renounced, have you had any issues/problems returning to the US to visit? Have you had to go to the embassy to apply for a visa to visit the US, or what kind of visa is required, and what is the maximum time one can visit the US as a non-citizen?


maplesandbox.ca has a long thread dealing with this question. You can access it at Crossing the US Border on a non-US passport showing a US birthplace | Maple Sandbox


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## USExpat111

Very interesting!!! Thank you very much, HillBillyCanuck!


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## BBCWatcher

shidareume said:


> Of course, one could simply ask people why they are motivated to renounce.
> Why looky here, someone has done just that....


The author does not claim that this survey is statistically representative. Here's the key quote: "The survey was an opt-in snowball survey, distributed initially via overseas American organizations." The survey included only 142 former U.S. citizens.

Like I said, there really are not good data here.


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## BBCWatcher

theOAP said:


> It would be foolish to think TurboTax will sort all this out (unless, of course, you’re Tim Geithner).


I don't understand the Geithner reference, but I quite agree that tax preparation software is not particularly useful in handling Expatriation Tax-related issues.


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## shidareume

BBCWatcher said:


> The author does not claim that this survey is statistically representative. Here's the key quote: "The survey was an opt-in snowball survey, distributed initially via overseas American organizations." The survey included only 142 former U.S. citizens.
> 
> Like I said, there really are not good data here.


Somehow, when it comes to predicting what people might be motivated to do if RBT were instituted, you have full confidence in your ability to understand what they would think and do. Yet when presented with actual statements from real people about their real, not hypothetical, motivations under a real, not hypothetical, set of circumstances, you become all skittish about methodological concerns. Oh no, couldn't possibly venture an opinion in that case.

I mean sure, any voluntary poll will have sampling issues, but let's face it, some pretty clear, strong trends are being evinced.


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## JustLurking

BBCWatcher said:


> I don't understand the Geithner reference, ...


Geithner Apologizes For Not Paying Taxes - CBS News


> *Geithner Apologizes For Not Paying Taxes*
> ....
> As to his failure to pay payroll taxes from 2001 to 2004 while he worked for the International Monetary Fund, Geithner said: "These were careless mistakes. They were avoidable mistakes."
> 
> "But they were unintentional," he said.
> 
> Geithner told the panel that, for the 2001 and 2002 tax years, he had prepared his tax returns himself with a popular tax-preparation computer program.
> ...
> "If Mr. Geithner got a pass on the penalty, he's a very lucky man," Sepp said.
> 
> What really rankled some senators is that only after Geithner knew he was Obama's pick for treasury secretary did Geithner go back and pay his social security taxes for 2001 and 2002 - nearly $26,000 more, Attkisson reports.


See also: Turbotax Timmy.


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## BBCWatcher

shidareume said:


> Somehow, when it comes to predicting what people might be motivated to do if RBT were instituted, you have full confidence in your ability to understand what they would think and do. Yet when presented with actual statements from real people about their real, not hypothetical, motivations under a real, not hypothetical, set of circumstances, you become all skittish about methodological concerns. Oh no, couldn't possibly venture an opinion in that case.


It is an entirely _reasonable_ supposition that many individuals will act in their own financial self-interests if given the opportunity. Tax avoidance behaviors are entirely predictable. I'm not the only one making that prediction. There are many experts who recognize the same problem. Congress recognized the problem as early as 1862, and it's a real problem (at least for Congress).

I have absolutely no doubt that some individuals are renouncing U.S. citizenship because they object to financial reporting. I never wrote otherwise. What I did write is that many individuals do not. How many? I don't know, and this particular unscientific, anecdotal survey doesn't help answer that question.


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## newthilde

BBCWatcher said:


> The author does not claim that this survey is statistically representative. Here's the key quote: "The survey was an opt-in snowball survey, distributed initially via overseas American organizations." The survey included only 142 former U.S. citizens.
> 
> Like I said, there really are not good data here.


The number isn't even the biggest problem - but it is likely not a representative sample (you could - theoretically - draw some conclusions from a small sample if it were representative). Of course, the problem is that it is really hard to get a truly representative sample. I would love to hear more about the reasons for renouncing too. I would assume (and this is totally a gut feeling) that the reasons are VERY mixed and range from tax/reporting, to not having been a 'real' American (a friend of mine was born in the U.S. but never lived there), to political reasons, to ...


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## maz57

BBCWatcher said:


> It is an entirely _reasonable_ supposition that many individuals will act in their own financial self-interests if given the opportunity. Tax avoidance behaviors are entirely predictable. I'm not the only one making that prediction. There are many experts who recognize the same problem. Congress recognized the problem as early as 1862, and it's a real problem (at least for Congress).


I don't think ANY kind of human behavior is entirely predictable, but if what you are saying is that most people will avoid tax whenever the opportunity presents itself, the US tax system must be in trouble because it relies largely on voluntary compliance. For US resident Americans withholding and 1099 reporting partially offsets this problem, but for expats there is no withholding (except for US source, of course) and virtually no reporting. You yourself have stated that the revenue collected from expats is critical to the US yet it is even more voluntary than homeland collection. The fact the US receives any revenue at all from its overseas citizens is a testament to the basic honesty and integrity of people because there is no way the US can actually enforce this.

Homelanders can basically do anything they want in a financial sense and as long as they pay the taxes due everything is good with the IRS. Expats who do similar things in their country of residence suddenly find they are in trouble because of all the extra reporting and punitive treatment of ordinary home country investments. 

Personally, my observation is that most people are decent, honest folks who try to do the right thing as long as they don't feel they are getting screwed in the process. In the case of expats, they must first know they are supposed to comply before they can even attempt it. When they finally do find out about US CBT and discover the full horror of US tax compliance for expats, that's when they start to do the calculation to determine whether continuing to be a US citizen is worth it to them personally. When you screw people and assume they are criminals that's when they start heading for the exits. This is abuse, pure and simple.

If the US switched to RBT, many of these renunciations would not happen. If the US kept CBT but eliminated the oppressive reporting and punitive taxation the result would be similar. I repeat my earlier statement that it is the reporting and the restriction of financial freedom that is at the root of many of these renunciations. The present exit tax (not to mention the $2350 fee) is designed to discourage and punish those who renounce yet people choose to renounce anyway. People are choosing to pay substantial sums to not be a US citizen. I don't see how the message could be stated more clearly. That is how much expats resent current US tax policy.


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## Nononymous

maz57 said:


> ...When they finally do find out about US CBT and discover the full horror of US tax compliance for expats, that's when they start to do the calculation to determine whether continuing to be a US citizen is worth it to them personally...


Or they say "screw you, Uncle Sam" and cheerfully carry on ignoring their filing requirements.


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## maz57

Nononymous said:


> Or they say "screw you, Uncle Sam" and cheerfully carry on ignoring their filing requirements.


Yup!


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## Nononymous

maz57 said:


> Yup!


Wouldn't want to give them the satisfaction of taking $2350 off me, to be honest.


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## maz57

Yes, going through all of the official hoops amounts to voluntarily painting a target on your own back. And the greater your net worth, the bigger the target.

Better to quietly relinquish or just fade into the surroundings. A few more years of this FATCA crap and it will be common knowledge how to avoid the whole mess. We are presently in a transition phase as people learn how to manage their exposure and how to deal with their bank if and when the subject comes up.

I imagine the number of informal, unofficial renunciants is several times the official published number. We'll never know; its sort of like the underground economy.


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## shidareume

BBCWatcher said:


> It is an entirely _reasonable_ supposition that many individuals will act in their own financial self-interests if given the opportunity.


Surely you will agree that it is also an entirely reasonable supposition that many individuals will act to reduce stress, complexity, arbitrary restrictions, and exposure to potentially crippling penalties even in the absence of actual tax owed.

In fact in this case, we don't even need to suppose. People are saying so.



> I have absolutely no doubt that some individuals are renouncing U.S. citizenship because they object to financial reporting.


It is not merely "objecting to financial reporting." Show more recognition of the pain of others, please.



> I never wrote otherwise. What I did write is that many individuals do not. How many? I don't know, and this particular unscientific, anecdotal survey doesn't help answer that question.


It provides more data than we have on how many people would move to the Caymans if RBT were enacted.


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## BBCWatcher

shidareume said:


> Show more recognition of the pain of others, please.


May I remind you that I've been perhaps the most vocal and active in this forum (and elsewhere) in criticizing FinCEN for having a difficult e-filing system, and I've been advocating for addressing that pain as one example. I've also advocated for -- and continue to advocate for -- combining financial reports into a single, consolidated report. I don't think there are many people in this forum who have been more active and constructive, in the proper venues, to address these issues.

Fortunately there's some recent good news here. FinCEN has now introduced a much easier FinCEN Form 114 e-filing system that appears to work on smartphones, tablets, PCs, and Macs without requiring proprietary plug-in software. I have some testing to do, but it appears to be exactly what filers wanted and needed.


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## JustLurking

BBCWatcher said:


> ...Fortunately there's some recent good news here. FinCEN has now introduced a much easier FinCEN Form 114 e-filing system that appears to work on smartphones, tablets, PCs, and Macs without requiring proprietary plug-in software. I have some testing to do, but it appears to be exactly what filers wanted and needed.


Sometimes you're too funny, BBCWatcher!

What filers want, exactly, is to not have to file any of this pointless busywork in the first place. FinCEN's recent _mild_ improvement to their own horrible process is a bandaid on a giant sucking chest wound.


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## BBCWatcher

And I want to pay zero taxes, have a bigger home, have world peace, and eat free cake every day.


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## Bevdeforges

Well, given that we're obviously NOT discussion any of the OPs specific questions anymore, I think we can put paid to this one....
Cheers,
Bev


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