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The Almighty Buck United States

Wealthy People Are Renouncing American Citizenship 210

An anonymous reader quotes a report from Axios: The number of Americans who renounced their citizenship in favor of a foreign country hit an all-time high in 2020: 6,707, a 237% increase over 2019. While the numbers are down this year, that's probably because many U.S. embassies and consulates remain closed for COVID-19, and taking this grave step requires taking an oath in front of a State Department officer. The people who flee tend to be ultra-wealthy, and many of them are seeking to reduce their tax burden. New tax and estate measures proposed by the Biden administration could, if implemented, accelerate this trend.

The IRS publishes a quarterly list of the names of people who have renounced their citizenship or given up their green cards, but it only includes people with global assets over $2 million. The numbers started swelling in 2010, when Congress passed the Foreign Account Tax Compliance Act, or FATCA, which increased reporting requirements and penalties for expats. But the Wall Street Journal discovered that the lists aren't up to date: A lot of people who were reported to have renounced citizenship in 2020 actually did so years earlier.
"Only the U.S. and Eritrea tax people based on citizenship rather than residency," notes Axios. "For most countries, if you are a citizen but don't reside there, you aren't taxed in that country."
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Wealthy People Are Renouncing American Citizenship

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  • Exit tax (Score:5, Insightful)

    by ShanghaiBill ( 739463 ) on Thursday August 05, 2021 @07:18PM (#61661655)

    The US imposes an "exit tax" on net worth above $2M.

    If you have high earning potential, it is best to renounce your US citizenship before you earn your money rather than after.

    U.S. Expatriation Tax [wikipedia.org]

    • The US imposes an "exit tax" on net worth above $2M.

      Not only that but you could become a target or pawn for the NSA or CIA. If you aren't a US citizen then you are fair game.

    • Re:Exit tax (Score:5, Insightful)

      by mysidia ( 191772 ) on Thursday August 05, 2021 @08:13PM (#61661855)

      The US imposes an "exit tax" on net worth above $2M.

      It's a sham that puts Immigrants to the US in a superior position to leave and avoid the tax and discriminates against the US-Born and levels against the upper middle class who may have a few million to their name after considering their primary residence.

      Particularly... People who immigrated to the US can entirely avoid the exit tax once they have lived outside of the US for more than 7 of the past 15 years; It applies to US Born Citizens and also Long term residents of 8 of the past 15 years, Anyone else like Naturalized citizens who may have become Uber-wealthy after 30 years in the US and then moved out of the US for 7 years are exempt from the exit tax.

      The Ultrawealthy with appropriate planning avoid or reduce it so much that the tax will not be what it sounds like on paper. The tax is a tax on the gain from personal holdings - the Ultrawealthy are capable of becoming a beneficiary of an offshore Trusts and LLCs, or specifically,
        Forming a contract where payment is made expecting future income but there is not an owned discernible asset of value redeemable for more than what it's paid for.

    • by dohzer ( 867770 )

      So what if the money you're paid never actually enters the US?

      • by PPH ( 736903 )

        So what if the money you're paid never actually enters the US?

        Therein lies the rub. If the IRS can prove you had overseas earnings, they can go back and seize them. Very wealthy people can set up overseas ownership structures to conceal such ownership. But since they have to be set up before the income starts to accumulate, that can be clear evidence of intent to commit tax evasion.

        • by GuB-42 ( 2483988 )

          Seize them? In a foreign country?
          What kind of right does the US has over stuff that is not in the US and never transited though the US?

          • by clovis ( 4684 )

            Seize them? In a foreign country?
            What kind of right does the US has over stuff that is not in the US and never transited though the US?

            It is a basic principle of a society based on democratic principles that the laws we create for ourselves apply to all of us who are citizens. That's where the right comes from - we gave it to ourselves.
            If you don't like it, leave and renounce your citizenship. The $2350 fee is far less than what the IRS would take every year.

            Setting aside my theoretical bullshit, taxing foreign income isn't really about making some factory worker in Canada pay US taxes because he was born here.
            It is about multi-multi- mil

          • This article has glossed over one of the other related annoyances of having US citizenship overseas. Many smaller banks have no desire whatsoever to put up with the paperwork they have to file for a US citizen account holder, so finding a bank that will take you as a customer is a PITA.

    • isn't this the reason why you see a lot of people moving money win crypto, art, or other medium that aren't heavily regulated or watched so closely? This isn't too far off from wealthy Chinese moving money out of China.
      another way I've heard of is setting up a foreign entity, that then sues you, as legal settlements aren't subject to tax in a lot of places, and can get around this sort of thing.

    • The US has the best socialist ideas sometimes.

  • Tom Barrack wished he had renounced his citizenship earlier, but he was on a DT gravy train he didn't want to let go .. https://www.cnbc.com/2021/07/2... [cnbc.com]
  • Non-resident taxes (Score:3, Insightful)

    by Goonie ( 8651 ) <robert...merkel@@@benambra...org> on Thursday August 05, 2021 @07:21PM (#61661673) Homepage
    I'm surprised it's that low.

    The US is almost unique in requiring non-resident citizens to pay income tax on their earnings (above a threshold of about $110,000). There are certain other provisions for non-residents to avoid double taxation, but it all gets pretty complex and you can understand why some wealthy Americans who can take out citizenship in their country of residence decide that it's easier to just renounce their US citizenship.

    • by Luckyo ( 1726890 ) on Thursday August 05, 2021 @07:52PM (#61661791)

      Complexity is such that it hits people who never were US citizens or held permanent residence there. I literally have to sign a document stating that "I have no US tax liabilities" with all my banks for example.

      It's quite ridiculous how much of an overreach US has on this issue.

      • Yeah I have to jump through a lot of hoops because of this shit too.

        I transferred some of my employer's shares to my personal brokerage account, which is EU based, but uses Interactive Brokers. I thought it was going through the Irish subsidiary, but the employer's account thinks otherwise and basically I can't confirm that I have "no US tax liabilities" because it sees the IBKR account. Is this correct? Will I be committing fraud if I just remove the account linkage? Will I go to joil next time I visit my

    • by Roger W Moore ( 538166 ) on Thursday August 05, 2021 @08:42PM (#61661977) Journal

      The US is almost unique in requiring non-resident citizens to pay income tax on their earnings (above a threshold of about $110,000).

      That's the really stupid thing about this though they do not really require them to pay tax since any foreign tax you pay on your income counts as a tax credit - even if the income is unearned - and the US generally has lower tax rates than most other western countries.

      So really the US just requires its citizens living abroad to fill in mountains of complex paperwork for little to no tax revenue. Worse, it threatens you with massive fines and imprisonment if you get anything wrong while at the same time providing zero advice on how non-US financial matters translate into the US system leaving to make an honest attempt and hope that will suffice. However, there are also some carefully placed traps e.g. any poor US citizen who innocently purchases a Canadian ETF or mutual fund while living in Canada will trigger a small avalanche of forms plus penalty taxes - and probably even more penalty taxes if they do not notice the trap until years later.

      So the "tax" US citizens pay is more one of stress and time worrying and figuring out how to do all the stupid paperwork and avoiding prison or fines. I would guess this is easier for those with $2M+ to pay an accountant to just fill it all in for them which is why you do not see more giving up their citizenship. What I would be interested to see is the statistics for those with under $2M in wealth since those are the ones really being hit by this nightmare.

      • by thogard ( 43403 )

        The paperwork is a mess. I can't be the treasurer of any of my clubs because that would require filling out a form providing the IRS details of those clubs since some of them sometimes have more than the equivalent of US$10,000 in a bank account. Joint businesses have the same threshold so if I loan a friend some cash for their business, it may need to be reported to the IRS. That gets very odd because if the business uses either imported products or exports another set of rules come inplay and those rule

    • by maglor_83 ( 856254 ) on Thursday August 05, 2021 @09:32PM (#61662101)

      The US is almost unique in requiring non-resident citizens to pay income tax on their earnings.

      After independence, the US suddenly cared a lot less about that no taxation without representation ideal.

      • Non-residents still get other benefits like Uncle Sugar assisting them via the local embassy when they do stupid shit. There are far greater benefits to US citizenship than a useless vote.

      • How are expats not represented? They're still entitled to vote.
        • Asking in ignorance; Hypothetically, what locality am I supposed to vote in if I'm a dual citizen that's lived in Ireland since I was 2?
          • by cmseagle ( 1195671 ) on Friday August 06, 2021 @10:01AM (#61663661)

            I believe you would vote based on wherever you lived when you were 1, before you moved to Ireland.

            It's a little more complicated if you're a citizen who has never resided in the US. Most, but not all, states will allow you to vote if it's where your parents most recently resided. Link. [fvap.gov]

    • above a threshold of about $110,000)

      The threshold (it's actually a deduction) only applies to earned income.

      • Yes, but that is only half the story.

        As others have said ther eare two other things to go with this. This is based on what is happening to a good mate of mine.

        1 - The reporting requirements. Just to prove he's not earning more than that amount, a good mate of mine has a MOUNTAIN of paperwork to be sent to the IRS. As others have mentioned, there is also a magic limit of $10,000 at any one instant (not a sustained period, like the moment he got paid) but in combined bank accounts (with wife) that also needs

  • In case you didn't know, renouncing one's citizenship costs you more in the US than everywhere else in the world [nomadcapitalist.com] - namely a flat fee of $2350. Meaning, as always, if you're not wealthy and you want to do what rich people do to avoid paying taxes, it costs you a lot more comparatively.

    • by MBGMorden ( 803437 ) on Thursday August 05, 2021 @08:26PM (#61661901)

      Immigration and gaining citizenship are completely different things though. I'm planning on moving out of the United States as soon as I retire (which is about 10 years away), but I damned sure won't be renouncing my citizenship.

      Being a US citizen just has too many advantages compared to a lot of countries in the world. That's why for this its mostly rich people doing it: they can afford to gain citizenship in another country with similar or better advantages (eg, Japan, Germany, Sweden, etc). Middle class people leaving the US are typically seeking places with cheaper costs of living that typically have less valuable passports (and poor people generally aren't leaving period - they simply can't afford it).

  • There is nothing this country can provide me I can't get elsewhere. Indeed I would be more secure almost anywhere in Europe without the threat of losing everything (again) to insurmountable medical debt. The US is critically broken and we have been reduced the same way the USSR was decimated by its corrupt government. Unchecked capitalism is just as destructive to a country as communism, perhaps more so. The same result in both cases. The wealth moves upward toward a few and the rest are at their mercy
    • Re: (Score:3, Funny)

      We have the best government money can buy,
      What's the problem?
      [sarcasm]

    • by Rosco P. Coltrane ( 209368 ) on Thursday August 05, 2021 @07:34PM (#61661723)

      Unchecked capitalism is just as destructive to a country as communism

      Hence the old Soviet satirical comment: "Capitalism is the exploitation of man by man; Communism is the exact opposite."

    • Re: (Score:3, Insightful)

      by calih71282 ( 8485049 )
      If you believed that....why wouldn't you go now? What difference does it make if you are rich or not? You would be "safe" in Europe. Seems like it would be more important to move if you were middle class or poor, because you are more likely to be wiped out if you incurred a sudden debt. You guys are all talk. You are afraid of leaving America.
      • Moving between two equal opportunities is not a zero cost ordeal. The OP is 100% correct. The USA provides nothing you can't get in many other places in the world, or even better. Heck having been around the world and lived in more countries than I can count on my appendages, this is true in some form or another of any civilised country.

        However I currently live in a country which costs me more to live in and results in a lower net wealth than another I could potentially choose. This does not mean I'm better

    • Re: (Score:2, Insightful)

      by Luckyo ( 1726890 )

      If you're rich, you're probably going to US for medical treatment, not leaving it. It's expensive, but you can get the latest and greatest treatment, rather than whatever public system has cleared you to have.

      • Re: (Score:3, Informative)

        Well ... maybe if you're super-rich you'd go to the US for medical treatment, but if you're only ordinary-rich, you might be better off getting care in another developed country: Ezekiel J. Emanuel et al., "Comparing Health Outcomes of Privileged US Citizens With Those of Average Residents of Other Developed Countries," JAMA Internal Medicine, March, 2021;181:339-44 From the Abstract: Objective To assess whether the health outcomes of White US citizens living in the 1% and 5% richest counties (hereafter
        • by Luckyo ( 1726890 )

          Devil of your study is in its details. Every treatment where you want newest, most advanced treatment to have improved chance of survival (for example breast and colon cancers), US leads.

          Every treatment where excellence of basic care is key, and/or lifestyle is more important (maternal mortality, childhood diseases), they lose.

          Conclusion: your study isn't measuring treatment quality for top tier medicine. It's measuring health outcome differences in basic care and typical lifestyles of each nation and how m

      • Well, here is an article about a small hospital in northern Germany that has patients from all over the world, including the US:

        https://www.weser-kurier.de/br... [weser-kurier.de]

        • by Luckyo ( 1726890 )

          Germany, Austria and Switzerland have a niche industry where there's a small handful of specific cancer treatments that are top of the world. Russia has a specific group of drug weaning treatments that are also top of the world.

          For pretty much everything else, you go to US for top of the world treatment. There may be a handful of other exceptions, as well as politically sensitive patients who go to Swiss clinics for treatment because travelling to US is either too risky or simply impossible.

    • insurmountable medical debt. What we talking 200k, never really heard of number larger than that? How many years of additional taxes in the UK is 200k, 4 or 5 years for me, Medical debt if paid off in 5 years does not seem all that much of a life changer. Once you become 45 and have the timer running on the income years you will realize taxes and benefits are not better than long term investments and flexibility.

      Let me introduce you to the concept called insurance. Medical insurance, Home Owners In
  • by gurps_npc ( 621217 ) on Thursday August 05, 2021 @07:31PM (#61661707) Homepage

    Look, if you do not have $2 million, then you are NOT wealthy. Even if you are making a million a year.

    If you pay no tax, and withdraw 4% of your account (standard suggestion for the wealthy) every year, you need at least $3 million a year to have a salary of $120,000.

    The IRS list contains 733 people, not 6k+

    That is still a lot of money, if not a lot of people. It has to be more than $1.4 billion, and is probably much more than $14 billion.

    But the problem is not severe and never has been.

    US Citizen has a lot of advantages, especially for the wealthy. Tons of countries love to invite people in, but they do NOT respect them, just the money. If you are fleeing to avoid taxes, you are NOT going to Canada, Western Europe, Australia, etc.

    Instead we are 3 kinds of places:
    1) Muslim countries, like the United Arab Emirate
    2) War torn places like Somalia
    3) Small high end luxury countries like Bermuda that cater to the wealthy at a high price. These want your money and everything is expensive.

    • by inode_buddha ( 576844 ) on Thursday August 05, 2021 @08:02PM (#61661823) Journal

      The taxes are pretty much the same across income brackets between the US and the EU, according to family and acquaintances who live and travel both ways. The real question is "What are you getting for those taxes?"

      IMHO Germany, Netherlands, and the Nordic countries are the best as far as actually having a good system for taking care of people. But of course, I am biased by my own ancestry.

      • Huh? No not at all. The taxes are wildly different. What is equal is the total cost of living. I pay taxes through the nose. On the flip side when I tore my Iliacus it cost me 0 EUR. When my kids go to school it will cost them 0 EUR. My wife is doing a masters degree. Okay that costs money. 2,000EUR. The end result after expenses is very similar, but this is all funded largely from taxes which are wildly different between the USA and EU when you calculate to the take home pay.

        In Europe the "tax" ultimately

        • by mjwx ( 966435 )
          In Europe, you're not paying for health care amongst other things. There are few, if any city or state taxes and a lot of Americans like to quote federal taxes only, forgetting about local taxes.

          Besides, nice cherry picking with the 100,000 Euro, try a closer to average wage of US$50,000 (around GBP 36,000) and you'll find the difference is a few grand at the very best, and as mentioned, we don't have to pay for health insurance no do I need to worry about starving if I lose my job.

          In the US, $118,000
    • I'll just add that if you're a billionaire and renouncing your US citizenship to avoid paying US taxes, what's your problem? How much frelling money do you frakking need? /rant

    • Expats (Score:5, Interesting)

      by JBMcB ( 73720 ) on Thursday August 05, 2021 @08:32PM (#61661933)

      Puerto Rico

      Low cost of living. You can import nearly anything you could want, and it's easy as supply chains/shipping networks piggyback on the US's, as import rules are similar, if not exactly the same. *Very* low taxes. A short plane or boat ride to a whole bunch of other Caribbean islands. A lot of US expats are landing there.

    • by Pieroxy ( 222434 )

      The problem doesn't just impact the rich or super rich. It impacts *everyone*. My three kids were born on US soil. They are de facto American. I've had to declare their revenue for 10 years now. Their revenue is zero for now but that's about to change. It already cost us 7.5k€ in lawyers to make sense of where to declare what as the system in France is quite different from the US.

      Soon they'll start working and the problem is going to be really important.

      Please explain to me what my kids are getting in

      • I guess the disconnect for me is whether you or your kids are only US citizens, not dual citizens with France and thus "stuck" dealing with US tax system because you have no other citizenship.

        If you and they are citizens of France and don't have any reason beyond some kind of tourism impulse to go to the US, what happens if you just ignore US tax law? Does the US come after you in France for unpaid taxes? In other words, what's the risk/problem here?

        I can see where it would matter if your kids only had US

    • Being a Citizen of most other countries allows you freedom to live in other places in the world without a tax burden. For example you list Australia, if you are an Australian citizen you have easy access to a lot of countries and Australia won't tax you if you choose to live and work overseas while being an Australian citizen and Australia has no death/inheritance tax.
  • For most countries, if you are a citizen but don't reside there, you aren't taxed in that country Talk about pwnage lol

  • by dhammabum ( 190105 ) on Thursday August 05, 2021 @07:54PM (#61661797)
    The really wealthy don't have to leave to avoid tax, they've adjusted the laws and regulations in their favor. I guess the IRS is looking for easier targets.
  • An overview (Score:4, Informative)

    by quonset ( 4839537 ) on Thursday August 05, 2021 @08:18PM (#61661867)

    This site [expatnetwork.com] gives a broad overview of what and how to renounce your U.S. citizenship. In short, you pay a fee ($2,350) AND an expatriation tax which is based on your assets the day before you renounce, with the first $699,000 being tax free. You also should have a passport from another country or you could be stateless.

  • The US policy of taxing non-resident citizens means those citizens pay US taxes without getting any benefits for it. It's not exactly taxation without representation, but it's something similar. Wasn't there a revolution about that?

    Of course, expat Americans have no real power, and stopping taxing non-resident citizens likely wouldn't be a popular move at home, so they are screwed.

    I am so glad I'm not a US citizen. My parents moved to the US when I was an infant, but luckily they saw the light and le

  • by schwit1 ( 797399 ) on Thursday August 05, 2021 @08:31PM (#61661925)

    Some countries do not allow dual citizenship [insider.com]. If you want to live there and be a citizen there you have no choice but to give up US citizenship.

    • Indeed it's complex. The list of countries are far larger than just the ones mentioned in your link, but critically that information in the link also tells only part of the story. E.g. in Europe many countries do not allow dual citizenship, but all of them are subject to an overriding EU law (including the Netherlands) which states you can keep dual citizenship if you are financially disadvantaged due to your status.

      I for one am a dual citizen of a country where where it is not allowed to be a dual citizen

  • The poor are less able to trade their US citizenship for foreign citizenship, so it is harder to avoid US taxes.

  • None was passed, but there has been quite a bit of talk about taxing wealth - which would of course need to be combined with a large tax on taking money out of the country. So its a pretty reasonable action to take if you are wealthy
  • Americans are waking up and realizing how fucked over they got by the 1%. They are getting grouchier and the rich ones don't want to wait until the pitchforks and torches are visible outside the big iron gates.

  • It's a disaster of a system, which Trump made worse with his "tax reform". Biden has, rather predictably, now made the situation even worse.

    The most fundamental of freedoms is the freedom to choose one’s own government. The US government, however, seems not to understand the concept of competition. You see, unlike the old USSR, the US does not deny this right. The US government is smarter than that, choosing instead to allow its valued citizens to migrate to other countries, and simply imposing US

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