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  • IRS Releases List Of Americans Hoping To Expatriate, Number Tops 1,000

IRS Releases List Of Americans Hoping To Expatriate, Number Tops 1,000

Kelly Phillips ErbAugust 11, 2013July 16, 2020

With all of the hubbub over Edward Snowden’s citizenship status, it’s easy to forget that there are thousands of Americans with slightly less remarkable circumstances who voluntarily opt to give up U.S. citizenship.

Under IRC section 6039G of the Health Insurance Portability and Accountability Act (HIPAA) of 1996, as amended, the Internal Revenue Service is required to post a list of citizens who voluntarily expatriate or abandon their American citizenship. The list is published each quarter in the Federal Registry.

Last quarter’s registry, published in May 2013, raised a number of eyebrows because it included the names of 679 citizens. That was the longest list of citizens opting to expatriate in more than 15 years.

Until this quarter. For the second quarter of 2013, the expatriation list includes a whopping 1,130 names. That’s almost twice the length of last quarter’s list and just shy of the record 1,208 names recorded during the second quarter of 1997. In contrast, the shortest list was published in the second quarter of 2009: just 15 names made the list.

It’s been widely speculated that most citizens on the list are leaving for tax reasons. That notion has been bolstered by the prior moves of such big names as Edward Tupper (yes, the founder of Tupperware), who bought an island off of Costa Rica to avoid taxes; Facebook co-founder Eduardo Saverin who bolted reportedly for Singapore to avoid capital gains; and Denise Rich, former wife of pardoned tax cheat and uber-wealthy Marc Rich, who expatriated to the U.K.

It’s worth noting, however, that not everyone who makes the list is fleeing for tax reasons. You can renounce your U.S. citizenship for a number of reasons including running for office in a foreign country (like Andreas Papandreou who went on to become the Prime Minister of Greece)) or to retain citizenship in a foreign country that doesn’t allow dual citizenship. You may also opt to give up your citizenship to protest U.S. policies or actions.

And while getting your citizenship back after you’ve renounced isn’t easy, it’s not impossible. Movie actress Elizabeth Taylor did it over a period of just over ten years. Taylor was a dual citizen of the U.S. and the U.K. by birth. During her first marriage to Sir Richard Burton, she attempted to renounce her citizenship but due to an alteration on the form, her renunciation was declared invalid. She signed another one a year later and that one stuck… However, in 1977, Taylor applied to be a U.S. citizen again while married to her sixth husband (seventh marriage since she was married to Burton twice), John Warner. Warner, who served as Secretary of the U.S. Navy during the Nixon Administration, went on the serve in the U.S. Senate where he served for nearly 30 years.

The next list will be made available sometime after the third quarter ends. Based on lag time for publishing of between 20 and 40 days, expect to see it sometime in November 2013.

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Kelly Phillips Erb
Kelly Phillips Erb is a tax attorney, tax writer, and podcaster.
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