1,781 Americans renounced citizenship in 2011, according to the Federal Register

The Federal Register has just published the names of 360 former Americans who renounced citizenship in the fourth quarter of 2011. This brings the total number of published renunciants for last year to 1,781, compared to 1,485 for 2010. This includes 499 from January to March, 519 from April to June, 403 from July to September, and 360 from October to December. Internal Revenue Code Section 6039G requires that “[n]otwithstanding any other provision of law, not later than 30 days after the close of each calendar quarter, the Secretary shall publish in the Federal Register the name of each individual losing United States citizenship (within the meaning of section 877 (a) or 877A) with respect to whom the Secretary receives information under the preceding sentence during such quarter.” It’s an open question whether this list is actually complete. The RenunciationGuide.com website has expressed concerns about the completeness and quality of the data. International tax lawyer Andrew Mitchel at one point concluded that this list should only contain “covered expatriates”, but later re-examined the issue and concluded that it contains the names of all former Americans who lost citizenship in the period in question.

Update: Andrew Mitchel also just put up some nice charts on his blog with the number of published renunciants by year and by quarter, going back to 2004.

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33 thoughts on “1,781 Americans renounced citizenship in 2011, according to the Federal Register

  1. My name is not on the list. I informed the Toronto Consulate on April 7, 2011, of my expatriating act on 28 February, 2011. So obviously the list is either inaccurate or belated.

    Moses said to Pharoah, “Let my people go!”

  2. yep, I’m thinking these stats leave of the majority of people who renounce!! Why? Because it would look really bad if you have 10k people running out the doors every year.

  3. @geeeez What are they going to do when the number approaches 100K. I’m certain that it would be that high if the process were streamlined. The current requirements of expatriation are so draconian, that many people will consider themselves no longer US without going through the process at all. Also, the consulates are bottle-necking the process with their slowness and the lack of available appointment slots. Furthermore, the number indicated in the list are likely only those who have completed the process with the IRS. What of those who only relinquish, like me, but who may never ever fill out the Form 8854, which is a violation of every human rights code on planet Earth? Will those people ever be put on the list? It appears that those who actually complete the Form 8854 are only a fraction of the total renunciants.

  4. My name isn’t on this “last quarter, 2011” list either. But my relinquishment date was Dec. 29, so there’s almost no chance Leviathan’s grinding wheels had worked their way through my paperwork, in time for my name to be on this quarter’s list. (but, neither have i rec’d my CLN, nor any other sign that Uncle is willing to “accept” my application).

    Do also note that the wording says something to effect of those “with respect to whom the [IRS/ Treas.] Secretary received information” of having given up citizenship, during the quarter concerned. Who knows how long it takes State to notify IRS…

  5. I believe Andrew Mitchel’s analysis is flawed or based on faulty data and/or assumptions. Besides myself, I know personally of four other people who terminated long-term permanent residency in the US in 2008. One most definitely did not complete any tax paperwork, but the others did. And I most certainly did — crossed t’s, dotted i’s, “sailing permit”, the absolute lot.

    Neither my name nor that of any of the others has ever appeared in the federal register’s “name and shame” list (and boy, what a distasteful and pathetic act creating this list was on the part of congress). So… either the list simply does not include long-term permanent residents, which Andrew Mitchel claims it does, or if it should then it is wildly under reporting. Either makes Andrew’s analysis suspect and therefore quite possibly wrong. Personally I don’t believe it. The federal register is merely the tip of the renunciation/expatriation iceberg.

  6. A published list? Does anyone know how long they have been publishing this list? Does anyone know if is is possible to see if my name is on the list from 1973?

    In keeping a low profile, I would like to find a way of finding that ancient list without actually contacting DOS.

    Was Superman on last year’s list? He renounced in April 2011. Even the New York TImes reported on it!

    http://artsbeat.blogs.nytimes.com/2011/04/29/superman-renounces-his-u-s-citizenship/

    Superman wasn’t born in the US, but he was a US citizen because Clark Kent’s adoptive parents were American. Superman has admitted he has stashed his assets in the Cooke Islands. Oh Oh, Superman, the IRS will find them there. Were you tax compliant when you renounced?

    Please join us in our fight here at Isaac Brock, Superman!

  7. @Watcher To be fair to Andrew, the law is very badly written, making it quite hard to interpret. I don’t even think the IRS knows what the law means. Only the Congresscritters who actually read the law before passing it (if there were any) might know that for sure. 6039G refers to “losing United States citizenship (within the meaning of section 877(a) or 877A)”.

    The thing is, 877A doesn’t use the term “losing citizenship” at all (it uses the terms “expatriate” and “relinquishing citizenship, but the term “expatriate” includes people who were never citizens in the first place). 877(a) does use the term “loss of United States citizenship”, but it does not define it. Even more confusingly, 877(a)(2) limits the application of 877(a) to a class of persons meeting some criteria. So the question is, does someone “lose citizenship within the meaning of Section 877(a)” if 877(a)(2) states that the 877(a) does not apply to that person? I have no idea. Neither does anyone else. So the executive branch will do whatever it wants with regards to this law …

  8. I tried to interpret it at one point as well. I *think* it’s only a list of covered expatriates, but the language is unclear.

  9. No, it’s not just covered expatriates. The guy from nostate dot com called the IRS and told them to put him on the list. I know the US is not telling the “whole” truth according to the numbers. They could easily make this list “whole”, but I doubt they ever will. It looks disgraceful to even have 1 person renounce citizenship. But they asked for it!!

  10. @geeez: Yeah, but he’s a crackpot who insisted on being put on the list. He may well be a one-off.

  11. @geeez and a broken man on a Halifax pier: Mike Gogulski actually is a covered expatriate. He says he answered “no” to the Form 8854 question about past 5 years’ tax compliance. In a more recent interview he said that he stopped paying US taxes before 2005 (he didn’t renounce until 2008)

    So even if the list is only supposed to include covered expatriates, his name would be on it.

  12. … and, yes, I am a crackpot too. That’s what all of this has done to me. I would also be very relieved to finally be on the US list of shame, Deckard!

  13. Hhahah calgary!!

    I think what Gorgulski did was just crazy. If I didn’t have a little boy that was born here, I wouldn’t go stateless in a million years. If you anger the wrong person, they’ll kick you back to where you came from, but you are no longer entitled to be there. It would be a mess. Him being covered.. ? Are you sure about that.

    I thought about calling the IRS and telling them to put me on the list to save the $450, but what about the CLN? I think the CLN is equivalent to the East German Exit visa nowadays!

    @Halifax pier – what’s a one-off?

  14. This is a beautiful thread. Big bow to Eric. Very germane to the standing question that festers over at USxCanada.

    Bad data signals a sorry state of affairs.

    More bad data is the $4.4 billion collected from 33,000+ under voluntary disclosure programs. With no breakdown provided, that data could mean just about anything.

    If you intend to use summary numbers to frighten quarry and to brand the targeted, trot out meaningless factoid evidence of tax cheating.

  15. If anyone is interested I am trying to pick a fight with two US tax lawyers over at Jack Townsend’s blog. The two lawyers Asher and Patrick won’t respond unless you use a real name. I am trying to promote Isaac Brock Society as much as possible.
    http://federaltaxcrimes.blogspot.com/2012/02/swiss-government-and-swiss-banks.html#comment-form
    Also someone should send an email Isaac Brock to the reporter at Politico who wrote that story about Anna Getty renounciating.
    http://www.politico.com/blogs/under-the-radar/2012/02/anna-getty-may-have-renounced-us-citizenship-113243.html

  16. @Tim, it depends on what is it about? If it is about the FACTA, I got screen prints to show them and I *CAN* use my real name. I hate the ******* FACTA and it is the #1 reason I’m going to renounce. If my bank here tells me they can’t service my basic accounts, I’m screwed. If they gave me a “US-limited” account, I’m screwed even more because people will be too scared to deposit money because the account is “different” (this is a small town where I live). But it depends on the “angle” of the lawyer. I’ll let you decide, Tim.

    I’m not trying to do anything illegal; I pay my fair share here. Like I have said at least 3 times on this blog, I know several Brazilians with offshore accounts. They declare them here because they want have any problems with the BC (Banco Central). *BUT* there are no threats, nothing, like the US does. In Brazil, threatening language like that can get someone suied in a minute. Not even the government here acts this way. It is so saddening to see a first-world country like the US acts this way.

    And no, where I live is NOT like Mexico, for any Americans or Canadians reading this. I like Mexico; I have visited Mexico DF and several regions. Mexico is a nice place to visit.

    But where I live, the majority of the people are descendants of southern Europeans, mostly Italians. I live in Minas Gerais, “and proud of it!”

  17. After fighting with them some more they seem to acknowledge this a is problem for expats but will “somehow” be worked out but in their mind the “real” problem is all the people with accounts in Switzerland and that should be the main focus of everyone’s attention. I just posted as “Tim” however one of them Patrick made a big deal how he “doesn’t” give the dignity of a response to those that post anonymously. I don’t think it is worthwhile to fight with them anymore. I think their views are reflective though of what a lot of the population in the mainland US thinks so that why I wanted to give them a hard time.

  18. This is though what Patrick has to say on Townsend’s blog:

    Dual citizens innocently caught up in this “clean up” process should be treated much more leniently, perhaps not penalized at all, just brought into compliance by amending US tax returns going back or simply filing back US tax returns. The burden would be on those types to establish their entitlement with severe penalties if it is later discovered that they did not satisfy the conditions of the amnesty. No amnesty for accounts held through entities or under nominee ownership.

    That would be fair and reasonable and shouldn’t be difficult to administer.

    My comments again: Ahem “perhaps” not penalized at all. PERHAPS PERHAPS Are you of your mind. I don’t think the likes of “Patrick” really understand the gravity of the situation.

  19. Tim, like I said, any “fall-out” cases of the FACTA, I”m here for you. The only thing better than me in this area are people that actually had their accounts closed. I was denied “opening”.

  20. I’ve been saying for awhile that these “Renunciation LIsts” are bogus. They are extremely undereported and follow seemingly no logic. I believe that the majority of people on the list are probably classified as “covered expatriates”. Do an internet search for any of the names that you find and you will notice that lots of them would seem to be people who are probably very well off. Others they probably just add because they felt like it, some are left out for the same reasons probably. Does anyone know if Terry Gilliam (ex Monty Python member) appears in this list somewhere? He renounced in 2008 or something and I imagine that he would have to be included since the publicity was so intense.

  21. “But a constitution of government once changed from freedom, can never be restored. Liberty, once lost, is lost forever.”

    – John Adams

  22. I think that there may be a significant time lag as to when you renounce and if and when your name is on the list. It is my understanding that the list is for covered expatriates, this will exclude most of us anyway. Next they need to determine if you are a covered expatriate, we supply them with form 8854, our answers to the questions on that form aid in that determination. For someone who renounces today, that form is not due until around June of 2013. Next they must process the form, any guess on how long that takes? My guess is that most of the numbers on the 2011 list are people who renounced in 2009 or 2010.

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