Record Number Of Americans Expected To Renounce Citizenship In 2017

Perhaps some of the disaffected Hollywood elites who threatened to leave the country after Hillary's staggering 2016 election loss have actually followed through on their childish temper tantrums after all...

According to a Bloomberg note today, a record 6,800 Americans are expected to renounce their citizenship in 2017, a 26% increase YoY and nearly 7x the pace set just 5 years ago.

In the third quarter of this year, 1,376 Americans renounced their U.S. citizenship, putting the annual tally on track to top 2016’s record, data from the Treasury Department show.


If this year’s fourth quarter mirrors that of 2016, when 2,365 people chose to expatriate, 2017’s annual tally would be 6,813. That’s a 26 percent rise from 2016’s total of 5,411—which was itself a 26 percent jump from 2015.

Of course, the uptick, unfortunately, has nothing to do with disaffected Hollywood elites but rather corresponds with Obama's passage of a 2010 law requiring foreign banks to disclose U.S. citizens.

"To some degree it is President Obama’s fault. It was Obama and the Democratic Congress that passed a law in 2010 that forced foreign banks to disclose U.S. citizens," says Mitchel.


When the law was passed, it appeared to be aimed at fat cats who sought to hide money in secret Swiss bank accounts. But today, it could affect nearly any of the 7 million Americans, who Mitchel says live abroad—many of whom are people of modest means.

As Fortune pointed out, the United States, unlike almost every other country in the world, taxes people on the basis of citizenship rather than residency.  So even if you spend all of your adult, wage-earning years on a remote tropical island with a 0% tax rate, if you were born in the United States, you still owe Uncle Sam your "fair share."  So, when all those sunbathing tax evaders had their Swiss bank accounts exposed in 2010 they started to renounce their citizenship in record numbers.

The cause of the defections, which led the U.S. to say so long last quarter to everyone from Jonathan Abbis to Anna Zwirner, is primarily the U.S. tax system.


When it comes to taxes, the United States is an outlier because, unlike nearly every other country, it taxes people based on nationality rather than residency. While U.S. citizens can claim credits with the IRS for what they pay to foreign tax authorities, those amounts are not always enough to offset what they owe.


U.S. expats also face the burden of annual filings with the IRS with the prospect of stiff penalties if they fail to comply.


According to international tax attorney Andrew Mitchel, those who deliberately fail to report foreign accounts to the IRS can face a fine of $100,000 or half the value of the account—whichever is greater. Meanwhile, there are a range of other penalties for small business owners abroad and for those with assets of more than $30,000.


"The IRS has been very gracious in saying they won’t take more than 100% of your money," says Mitchel, ironically. "These people are terrified they will go bankrupt because of the United States. They just want to get out of the U.S. tax system."

And while we know many of you will be disappointed that our disaffected celebs aren't the key driver of the data above, we encourage you to keep an eye on this IRS list of American quitters...perhaps Lena Dunham's name will show up on there yet.


Ben Burnyankme Killer the Buzzard Fri, 11/03/2017 - 21:38 Permalink

WTF.  Intellectual idiocy alive and well here too at ZH.  Juis sangunis is the only thing that makes sense.  You are what your parents are.  Not the shit of Juis soli where you get the citizenship of where your mother actually gave birth to you.  How's that worked out?  As a person who was born here but who's blood and citizenship is of another country, I can't escape the curse of Uncle Samuelstein hunting me down around the world for taxes if I decided to leave the USSA.  Oh right, some of you morons don't believe in personal property and keeping what you make despite your protestations to the contrary.Those who are argue GTFO, go try to open a bank account even if you are a citizen of another country and have their passport.  The bank will still want you to produce your USSA SS card when they read in your passport that you were born in the Gulag Archipelago.  How's being free working out?  I don't blame anyone for giving the finger to Uncle Sam.

In reply to by Killer the Buzzard

GoldBricker Ben Burnyankme Sat, 11/04/2017 - 09:03 Permalink

Thanks Ben,

For slapping the dumbasses who've never lived anywhere else and never will, who've never had to learn another language or how to manage in another system. ZH used to have good commenters (check to see how long I've been around); now it's mostly trolls, shills, and bots. Yes, I'm talking to you; if you're young, start planning to get out now; you can always stay if things get better and America gets great again.

The mrs. and I got out in '99, just renounced this year (our names didn't show up on the register, making me think they're under-reported, but then, gov stats are worth the electrons they're printed on). Europe is fucked up too, but the USA is always ahead of the curve, especially in that department.

For the dumbasses, take another hit of Oxy and enjoy your Obamacare next time you're sick. At least the EU countries might be able to join the Russia-China One Road thingy.

Yes, I wish Trump well, though nobody could bring this thing back from the brink, maybe he'll buy us a few more years of potemkin-village normalcy. (If you don't know what a Potemkin village is, look it up. I won't call you a dumbass because you're probably the product of unionized public-school teachers, and are hence uneducated.

I went through that system in the 60s, and it was bad enough then; we were taught that the Vietnam War was a good thing. Yeah well, Vietnam fell to the communists and nothing happened; it was all a lie. Fast-forward to now and nothing has changed.

I better stop now. The smartphone generation won't even have read this far.

Peace and love to all,

In reply to by Ben Burnyankme

GoldBricker Promethus Sat, 11/04/2017 - 12:58 Permalink


I'm sorry now that I spoke harshly to that guy who called me a fat old cunt. At least I'm not fat.

Seriously, though, getting out is not easy, especially if you're older (I was 44 when I left) and not wealthy. I was lucky to have a portable skill and access to an EU passport.

I'm sorriest about slandering opiate addicts. Had I stayed, I might well be among them now. Sorry.

All that said, if you have a notion to go abroad, try it. If you don't make it in the end, you won't have lost much.

Netherlands as a great country, one of the free-est, richest, most tolerant places in the world for the last 5 centuries; how many places can match that? Cannabis legal since 1972. You feel safe on the street. When the EU breaks up, I'm betting that it will come through OK. Also, Dutch is not too difficult, unlike most languages further east. You want to stay in northern Europe, if Europe's your destination.

Go onto google street view and look at ordinary streets in Rotterdam or The Hague. In fact, do that wherever you think you might want to live and you'll get an idea whether it looks slummy or not.

Central & S. America are popular for US expats, but you'll need your own source of income (remote work, savings, pension) because the local economy is likely to be poor. Also, could be unstable and turn bad after you're settled (Brazil, for example, has gone down a lot in the last 10 years). If you're good with languages, I'd consider Russia.

It's true that muzzies are invading Europe in a big way, but the distribution is uneven. The muzzies I meet, I generally like; at least they're not trans-whatever, state-loving, zionist-obeying liberals. Also, they consider moneylending a sin; imagine that. Their women are wholesome looking, not decked out in purple hair, makeup, or tats (actually you couldn't see the tats anyway, since they cover up).

In reply to by Promethus

EnragedUSMCExpat Ben Burnyankme Sun, 11/05/2017 - 17:36 Permalink

American expats, due to their very nature and proven success in gaining their freedom in a foreign country are proof that banks are not necessary to survive out here, especially in ASEAN. Fuck that bullshit - banks are representatives of the satanic globalist cabal we have rejected. Being free is working out just fine and those that disparage our freedom are nothing more than jealous cowards too fearful or stupid to make the jump. Freedom is the only thing that matters.And don't worry, their plight will be the last thing on my mind as I drift this AM over the Sulawesi corals spearing our breakfast. The viz this AM is about 125+, the Bintang on ice.

In reply to by Ben Burnyankme

Weisshorn Killer the Buzzard Sat, 11/04/2017 - 09:57 Permalink

"DON'T.LET.THE.DOOR.HIT.YOU.ON.YOUR.ASS.ON.THE.WAY.OUT"Ignorant Yankees who have no clue and are bitter because someone else might escape the US tax slave plantation, more stupid than Lenin's famous "useful idiots". My son, father of 4, cannot get a home loan or open any bank account that does more than hold cash.  He would love to buy a house but can't, and he would like to buy some stocks.  No Swiss bank will do anything for him because he is a US person and has a US pass.  He has lived in Switzerland since he was 2.  The US province of the Zio-empire demands $2500 and possibly a deemed death and death taxes from him for the privilege of no longer being a US tax donkey, even though he hasnt' 5% of his life there in over 30 years.

In reply to by Killer the Buzzard

Number 9 Raffie Fri, 11/03/2017 - 18:40 Permalink

Of course, the uptick, unfortunately, has nothing to do with disaffected Hollywood elites but rather corresponds with Obama's passage of a 2010 law requiring foreign banks to disclose U.S. citizens.

if i had a business and was living away from the us and was being hamstrung by these draconian laws, i would bail in a heart beat..
still might

In reply to by Raffie

dark fiber Number 9 Fri, 11/03/2017 - 20:19 Permalink

FATCA applies to US persons not citizens.  You do realize that Swiss banks are turning away Swiss citizens because they happened to have a green card for a three month job in the US five years ago?  If they think renouncing will change anything they are class A clueless all American dumbasses.

In reply to by Number 9

BarkingCat dark fiber Fri, 11/03/2017 - 20:47 Permalink

You are correct on the first statement about US persons but incorrect about having green card for 3-month job. You don't get a green card  just because you get a job for 3 months.Also if you do have a green card, meaning you are a permanent legal resident, your status is revoked if you leave the US for more than a year. So if you get a job outside of the United States, you have to come back on the annual basis or you'll lose your permanent residence status. Actually even if you leave for a few years and come back once a year your status who still be very questionable and you might have to do some paperwork to ensure that you don't lose it.  so if you're a Swiss citizen or any other none US citizen, and are living outside the US and do not have US citizenship nor and active green card you have nothing to worry about as far as problems with opening up a bank account in a foreign country

In reply to by dark fiber

Déjà view dark fiber Sat, 11/04/2017 - 02:24 Permalink

If you expatriated on or after June 17, 2008, the new IRC 877A expatriation rules apply to you if any of the following statements apply.

Your average annual net income tax for the 5 years ending before the date of expatriation or termination of residency is more than a specified amount that is adjusted for inflation ($151,000 for 2012, $155,000 for 2013, $157,000 for 2014, and $160,000 for 2015).
Your net worth is $2 million or more on the date of your expatriation or termination of residency.
You fail to certify on Form 8854 that you have complied with all U.S. federal tax obligations for the 5 years preceding the date of your expatriation or termination of residency.

If any of these rules apply, you are a “covered expatriate.”

For long-term residents, as defined in IRC 7701(b)(6), a long-term resident ceases to be a lawful permanent resident if:

the individual’s status of having been lawfully accorded the privilege of residing permanently in the United States as an immigrant in accordance with immigration laws has been revoked or has been administratively or judicially determined to have been abandoned, or
the individual:
commences to be treated as a resident of a foreign country under the provisions of a tax treaty between the United States and the foreign country,
does not waive the benefits of the treaty applicable to residents of the foreign country, and
notifies the IRS of such treatment on Forms 8833 and 8854.
IRC 877A imposes a mark-to-market regime, which generally means that all property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date.  Any gain arising from the deemed sale is taken into account for the tax year of the deemed sale notwithstanding any other provisions of the Code.  Any loss from the deemed sale is taken into account for the tax year of the deemed sale to the extent otherwise provided in the Code, except that the wash sale rules of IRC 1091 do not apply.

The amount that would otherwise be includible in gross income by reason of the deemed sale rule is reduced (but not to below zero) by $600,000, which amount is to be adjusted for inflation for calendar years after 2008 (the “exclusion amount”). For calendar year 2014, the exclusion amount is $680,000.

Significant penalty imposed for not filing expatriation form

The Internal Revenue Service reminds practitioners that anyone who has expatriated or terminated his U.S. residency status must file Form 8854, Initial and Annual Expatriation Information Statement, and its Instructions. Form 8854 must also be filed to comply with the annual information reporting requirements of IRC 6039G, if the person is subject to the alternative expatriation tax under IRC 877 or IRC 877A. A $10,000 penalty may be imposed for failure to file Form 8854 when required.

IRS is sending notices to expatriates who have not complied with the Form 8854 requirements, including the imposition of the $10,000 penalty where appropriate.

The Instructions for Form 8854 provide details about the filing requirements, related definitions and line-by-line instructions for completing the form. Failure to file or not including all the information required by the form or including incorrect information could lead to a penalty.


In reply to by dark fiber

HRClinton Raffie Fri, 11/03/2017 - 19:59 Permalink

We're not "Trump" haters, but we do h8...TBTJTBTFDNC, Clintons, BushesSanctuary CitiesRINOsFED, IRSDHS, CIAMICMSMHollyweirdSnowflakes, SJWsAIPAC etcGS, JPMInner Cities (crime, welfare, building erosion)MonsantoHealth Insurance racket (overpriced, under-performing)Education racket (overpriced, under-performing)Elder Care racket (overpriced, linked to person's Global Assets, instead of Income)Corporate Welfare QueensSpoiled, pampered Entertainment millionaires (pro sports, TV, Media)Trash TV (brought to you by your Ashki masters)... Shall I keep going?Do you really think that my ability to buy guns (that I don't need and hope to never need), overcomes all this? If so, you're messed up and need Therapy more than the Liberals and Snowflakes do.And let's not overlook the OPPORTUNITY COST of spending another $5000 on guns & ammo, that I could have spent on BTC in 2010-2014. --> Bad finance, bad decisions.  Fuck the guns, and fuck your warped Mil or Frontier/Cowboy mentality of Bang, Bang, Bang! The world is fed up with your Banging! 

In reply to by Raffie

amadeus39 Fri, 11/03/2017 - 18:31 Permalink

Check their ethnicity. If jewish and destination is China, then the game of global power is thankfully over for the USA,  Like rats leaving a sinking ship. Jews will always follow the money, and china is where its at. Good luck to them both.  

Global Douche wildbad Fri, 11/03/2017 - 20:25 Permalink

Although misspelled, they're on my short list. Nice place, excellent weed, their Spanish language has a distinct dialect. They have the four seasons going for them, renewables are high on their agenda (wind energy, a specialty of mine, now claims around 1/3rd of their energy usage) and you get to enjoy Christmas in Summer!

In reply to by wildbad

GoldBricker falconflight Sat, 11/04/2017 - 09:12 Permalink

Try getting into some computer specialty. That was my ticket out; all the programs, docs, etc. are in English, so basic conversation in the local language is usually enough. If you don't like computers, look on the web for jobs teaching English.

I agree about S. America; my wife and I thought about Brazil in 2005, but we didn't know if we had another language in us (having had to learn 2 already). But I'm glad now that we didn't go, but stayed in Europe. At least we have good medical.

Learning to live abroad never ends. Learning a different language as an adult never ends. But it's worth it. Once you get a foothold abroad, you're not likely to go back.

Face it, America hates you if you are white, male, and not-rich.

In reply to by falconflight

pc_babe Fri, 11/03/2017 - 18:33 Permalink

Start from the top..

... be gone already

Of course, Obama can't give up what he never had.