International Tax Blog

2017 Fourth Quarter Published Expatriates – First Annual Decrease in Five Years

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2017. The number of published expatriates for the quarter was 685, bringing the total number of published expatriates in 2017 to 5,133. 2017 is the first year since 2012 where there has been a year-over-year decrease in published expatriates. The total for 2017 represents a 5% decrease versus 2016,... Read more →

2017 Third Quarter Published Expatriates – A Total of 1,376

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2017. The number of published expatriates for the quarter was 1,376. The number of published expatriates for the first three quarters of 2017 has been 4,448 (1,313 + 1,759 + 1,376). In the first three quarters of 2017, there has already been more published expatriates than there was for... Read more →

2017 Second Quarter Published Expatriates – Second Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2017. The number of published expatriates for the quarter was 1,759, which is the second highest quarterly number ever (second only to the fourth quarter of 2016 which had 2,365 published expatriates). The number of published expatriates for the first two quarters of 2017 has been 3,072 (1,313 +... Read more →

2017 First Quarter Published Expatriates – A Total of 1,313

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2017. The number of published expatriates for the quarter was 1,313. The data released today follows four consecutive years where new records were set for the number of expatriates. In 2013, there were 2,999 published expatriates, and last year there were 5,411 published expatriates. For a discussion of how... Read more →

2016 Fourth Quarter Published Expatriates – New Annual Record

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2016. The number of published expatriates for the quarter was 2,365, bringing the total number of published expatriates in 2016 to 5,411. The total for the year breaks last year’s record number of 4,279 published expatriates. The number of expatriates for 2016 is a 26% increase over 2015 and... Read more →

2016 Third Quarter Published Expatriates – Second Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) for the third quarter of 2016. The number of published expatriates for the quarter was 1,380, the second highest quarterly number ever. The highest quarterly number was the third quarter of 2015, with a total of 1,426 expatriates. The number of published expatriates for the first three quarters of 2016 has been 3,046 (1,158... Read more →

2016 Second Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2016. The number of published expatriates for the quarter was 508. The number of published expatriates for the first two quarters of 2016 has been 1,666 (1,158 + 508). For a discussion of how the IRS compiles the data, see this post. We continue to believe that the IRS... Read more →

Over 1,000 Published Expatriates in 2016 Q1 - The New Normal

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2016. The number of published expatriates for the quarter was 1,158. Only a few years ago, we would have been surprised by such a large quarterly number. Now having over 1,000 published expatriates per quarter appears to be the new normal. The data released today follows three consecutive years... Read more →

New Expatriate Record for 2015 – Nearly 4,300 Expatriations

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2015. The number of published expatriates for the quarter was 1,058, bringing the total number of published expatriates in 2015 to 4,279. The total for the year breaks last year’s record number of 3,415 published expatriates. The number of expatriates for 2015 is a 25% increase over 2014 and... Read more →

The Escalation of Offshore Penalties Over the Last 20 Years

Over the past twenty years, the U.S. has significantly increased the penalties associated with failing to report certain foreign-related transactions, and it has created new filing requirements that have their own associated penalties. The increase in penalties has occurred for tax return filing requirements as well for the FBAR (FinCEN Form 114, formerly TD F 90-22.1). The chart above (PDF) shows the penalties that an individual could be subject to in selected years if the... Read more →

2015 Third Quarter Published Expatriates – A Record High

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2015. The number of published expatriates for the quarter was 1,426. This is the highest quarterly number of published expatriates ever, surpassing the previous record of 1,335 that was set earlier this year (Q1 2015). The number of published expatriates for the first three quarters of 2015 has been... Read more →

Is the IRS Missing Names From Its Quarterly Publication of Expatriates?

We believe that the IRS is likely missing a significant number of names from its quarterly publication of expatriates. First, based on data recently released by the State Department and the FBI, the estimated number of Certificates of Loss of Nationality (“CLNs”) applied for or issued during the fiscal year ending September 30, 2015 (the “2015 Fiscal Year”) is roughly 6,000. However, for the first 3 quarters of 2015 Fiscal Year, the IRS has only... Read more →

2015 Second Quarter Published Expatriates – Lowest in Years

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2015. The number of published expatriates for the quarter was 460, which is the lowest amount of published expatriates in any quarter since the 4th quarter of 2012 where only 45 names were listed (and we speculated that the government made a reporting error). After a record number of... Read more →

The Exodus Continues (2015 1st Quarter Published Expatriates)

We began tracking expatriations in late 2009 because we anticipated that the number of expatriations would increase as a result of changes in U.S. tax laws and due to "saber rattling" by the IRS about the imposition of potential penalties in the wake of the UBS scandal. Our prediction has been accurate. Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the... Read more →

2014 - More Expatriations Than Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2014. The number of published expatriates for the quarter was 1,062 (second highest quarter ever), bringing the total number of published expatriates in 2014 to 3,415. The total for the year breaks last year’s record number of 2,999 published expatriates. The number of expatriates for 2014 is a 14%... Read more →

2014 Third Quarter Published Expatriates – Third Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2014. The number of published expatriates for the quarter was 776, which is the third highest quarterly number of published expatriates ever. The number of published expatriates for the first three quarters of 2014 has been 2,353 (1,001 + 576 + 776). Last year there was a record-breaking number... Read more →

Famous Tax Quotes - Taxing Citizens by Reason of Citizenship

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: The United States was historically and continues to be virtually unique in taxing its citizens, wherever resident, on their worldwide income, solely by reason of their citizenship. Crow v. Commr., 85 T.C. 376 (1985) Read more →

2014 Second Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2014. The number of published expatriates for the quarter was 576. The number of published expatriates for the first half of 2014 has been 1,577 (1,001 + 576). Last year there was a record setting 2,999 published expatriates. For a discussion of how the IRS compiles the data, see... Read more →

2014 First Quarter Published Expatriates - Second Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2014. The number of published expatriates for the quarter was 1,001. This is the second highest quarterly number of published expatriates ever and is only surpassed by the second quarter of 2013. For a discussion of how the IRS compiles the data, see this post. Last year there was... Read more →

Famous Tax Quotes - Expatriation is a Serious Act

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: [E]xpatriation is a serious act that should be undertaken with a full understanding of the consequences. Dacey v. Commr., TC Memo 1992-187. Read more →

Quarterly List of Expatriates: Source of Data

Last week the IRS released the names of individuals who renounced their citizenship or terminated their long-term U.S. residency. People often wonder how the I.R.S. receives the data and whether the list only includes individuals who are subject to the “exit tax.” Section 6039G(d) of the Internal Revenue Code (the “Code”) provides that the individuals listed in the Federal Register include: "[E]ach individual losing United States citizenship (within the meaning of section 877(a) or 877A)... Read more →

2013 Expatriations Increase by 221%

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2013. The number of published expatriates for the quarter was 630, bringing the total number of published expatriates in 2013 to 2,999. The total for the year shatters the previous record high of 1,781 set in 2011 and is a 221% increase over the 2012 total of 932. We... Read more →

2013 Third Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2013. The number of Published Expatriates for the quarter was 560. The number of published expatriates for the first three quarters of 2013 has been 2,369 (679 + 1,130 + 560). As stated last quarter, 2013 will clearly be the year with the highest number of published expatriates ever.... Read more →

Number of Expatriates Skyrockets Again (Second Quarter of 2013)

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2013. The number of Published Expatriates for the quarter was 1,130. This is the highest quarterly number of Published Expatriates ever. The number of published expatriates for the first two quarters of 2013 (1,809) has already exceeded the highest number of annual published expatriates ever (1,781 in 2011). Thus,... Read more →

Q1 2013 - Highest Quarterly Number of Expatriates Ever (But . . . )

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2013. The number of Published Expatriates was 679. This is the highest quarterly number of Published Expatriates ever. However, the prior quarter number of expatriates (Q4 2012) was only 45. For the 8 quarters prior to the fourth quarter of 2012, the average number of names listed per quarter... Read more →