International Tax Blog

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 →

48% Decrease in Number of Expatriates for 2012

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 2012. The number of Published Expatriates for the fourth quarter of 2012 was 45, and in 2012 the total number of expatriates was 932. The number of expatriates for 2012 decreased by 48% compared to 2011. The following graph shows the annual number of Published Expatriates from 1998 to... Read more →

Expatriates for the Third Quarter of 2012

Today the Treasury Department published the names of certain individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the third quarter of 2012. The number of Published Expatriates for the third quarter of 2012 was 238. The following graph shows the quarterly number of Published Expatriates since 2005. Read more →

189 Published Expatriates for Q2 of 2012

This past Friday the Treasury Department published the names of certain individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2012. The number of Published Expatriates for the second quarter of 2012 was 189, which is the lowest quarter number in the past 8 quarters. The following graph shows the quarterly number of Published Expatriates since 2005. Read more →

Links to Expatriate Lists

Below are links to the quarterly publications of individuals who have chosen to expatriate: December 31, 1996 (published January 30, 1997) March 31, 1997 (published April 30, 1997) June 30, 1997 (published July 22, 1997) September 30, 1997 (published November 4, 1997) December 31, 1997 (published February 9, 1998) March 31, 1998 (published September 8, 1999) June 30, 1998 (published August 11, 1998) - Duplicate of 4th quarter 1997 list published in error June 30,... Read more →

Update on 1997 Expatriation Data

Today Curtis Poe at overseas-exile.com kindly notified me of certain comments made in a February 2003 Joint Committee on Taxation report titled “Review of the Present-Law Tax and Immigration Treatment of Relinquishment of Citizenship and Termination of Long-Term Residency” JCS-2-03. In the GAO response to questions posed by the Joint Committee on Taxation, the number of U.S. citizens expatriating for the years 1991 to 1999 was listed in a table. However, the years 1995 to... Read more →

Example of a Mini-Eduardo Saverin

So let’s say you are a wealthy U.S. citizen living in Singapore (I am not an advisor of Eduardo Saverin and I have no information about his situation). You have $100,000 to invest over the next two years. You want to keep your life as simple as possible, so you decide that you will invest the funds in a single Singapore mutual fund. The mutual fund invests in stocks and securities in the Southeast Asian... Read more →

460 Published Expatriates for Q1 of 2012

Yesterday the Treasury Department published the names of certain individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2012. 5/14/12 Update: Facebook co-founder, Eduardo Saverin, was on the first quarter 2012 list of published expatriates. According to Saverin’s spokesperson, Saverin’s renunciation was prompted not by tax considerations but by U.S. rules that make it more difficult for U.S. citizens to live and invest overseas. See WSJ... Read more →

1997 Had More U.S. Expatriations Than 2011

CORRECTION: 1997 data not reliable and not comparable. To see update click here. Today I finished updating my expatriation graph back to 1997, the first full year that expatriation data was published in the Federal Register. After looking at the data, I was quite surprised to see the big spike in 1997, with 1,812 expatriations. The second quarter of 1997 alone had 1,205 expatriations. In looking at the names listed in the federal register for... Read more →

Number of Expatriates for 2011

See here for updated expatriates chart 1997 - 2011 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 2011. In 2011, the total number of expatriates was 1,781, a 16% increase from 2010. Last year had the highest number of expatriates since at least 2004 (when I started keeping these records), and perhaps the most in any year... Read more →