International Tax Blog

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 →

This Post Has Been Updated

See Quarterly List of Expatriates: Source of Data. Read more →

New Brunswick Premier Caught in U.S. Tax Net

New Brunswick’s Premier (a premier is a province's head of government, much like a governor of a state in the U.S.), David Alward, recently announced that he is filing U.S. tax returns back to 2003. Alward is a dual U.S./Canadian citizen. He was born in Massachusetts, but has not resided in the U.S. since he was quite young. An article by the Telegraph-Journal mistakenly attributes Alward’s current need to file U.S. tax returns with the... Read more →

Q2 of 2011 Had the Second Highest Number of “Published Expatriates”

Earlier this month 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 2011. For convenience, the expatriated individuals who have had their names published in the Federal Register are referred to as “Published Expatriates.” The number of Published Expatriates for the second quarter of 2011 was 519. This is the second highest number of quarterly Published Expatriates during... Read more →

This Post Has Been Updated

See Quarterly List of Expatriates: Source of Data. Read more →

U.S. Citizens Continue to Renounce

Last month the Treasury Department published the names of individuals who renounced their United States citizenship or terminated their long-term U.S. residency (“expatriated”) during the quarter ending March 31, 2011. A total of 499 individuals expatriated during this quarter. While 499 is not the highest number of quarterly expatriates in recent history, the quarterly average number of expatriates continues to increase. The following graph shows the quarterly average number of expatriates for the past 4... Read more →

Number of Expatriates More Than Doubles

The number of individuals expatriating from the U.S. more than doubled in 2010. Expatriating individuals include people that either renounce their U.S. citizenship or terminate their long-term U.S. permanent residency. In 2009, the total number of expatriates was 742. In 2010, the number increased to 1,534 --- a 207% increase. Last year had perhaps the highest number of expatriates in any year in U.S. history. I anticipate that this trend will continue. Shown below is... Read more →

Expatriations Continue Upward Trend

The number of individuals expatriating continues its upward trend. During the first quarter of 2010, a total of 179 individuals either renounced their U.S. citizenship or turned in their green cards. While the number of expatriates in the first quarter of 2010 was substantially below the prior quarter’s historic high of 502 expatriates, the number of expatriates was still high. Excepting the fourth quarter of 2009, the number of expatriates in the first quarter of... Read more →

U.S. Expatriations Skyrocket

Last fall I had a feeling that the number of U.S. expatriations would be increasing, due to recent tax law changes. I began tracking the number of expatriations, which appeared to be on the rise. Today the Treasury Department published the names of individuals who renounced their United States citizenship (“expatriated”) during the quarter ending December 31, 2009. A total of 502 individuals expatriated. This is the highest quarterly number of individuals expatriating for many... Read more →

Expatriations on the Rise Again

Today the Treasury Department published the names of individuals who renounced their United States citizenship (“expatriated”) during the quarter ending September 30, 2009. A total of 158 individuals expatriated. This is the highest number of individuals expatriating in more than four years. The following graph shows the number of expatriates for the past 4 years. The increase in expatriations may partially result from last year’s changes to the expatriation rules under the Heroes Earnings Assistance... Read more →

New Expatriation Rules for High Net Worth Individuals

Last week, President Bush signed into law H.R. 6081, the Heroes Earnings Assistance and Relief Tax Act of 2008. One provision of this act dramatically changes the U.S. taxation of high net worth individuals that renounce their U.S. citizenship, or cease to be long term U.S. residents (“expatriates”). In general, the provision imposes a “mark-to-market” tax on high net worth expatriates. Such individuals are subject to income tax on the net unrealized gain in their... Read more →