OVERVIEW -

One of the news items that generates political fireworks each year is the number and names of famous Americans who renounce their U.S. citizenship. According to the Wall Street Journal, the United States is on track to have the largest number of expatriations in history. In the second quarter of 2013, 1,130 names appeared on the list of those Americans or permanent residents who renounced U.S. citizenship or residency. In the first quarter of 2013, 679 Americans renounced their citizenship or permanent residency. The number of those renouncing their citizenship in the second quarter of 2013 was more than in all of 2012. Moreover, some observers and commentators have pointed out that these numbers may be incomplete; that to date, the IRS has failed (either by mistake or with purpose) fully to disclose all the expatriations.

Regardless of one’s political persuasion — liberal or conservative — the topic of expatriation generates a lot of conversation. For some, it is a reaction to the belief that the United States is headed in the wrong direction. For others, it is a negative reaction to what the United States stands for in the world.

Originally published in Tax Management Estates, Gifts, and Trusts Journal on September 12, 2013.