Americans on Pace for Record Year in Renouncing Citizenship

By Joe Palazzolo Features Dow Jones Newswires

The U.S. is on pace to see a record number of Americans shed their citizenship for the fifth year in a row, as the Internal Revenue Service expands its reach overseas.

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More than 4,400 Americans renounced their citizenship in the first three quarters of 2017, including about 1,370 in the quarter that ended on Sept. 30, according to an Internal Revenue Service report published Thursday in the Federal Register.

Compared with the roughly 320 million people who live in the U.S., the expatriations amount to a water molecule in the bucket, but the trend has been dramatic.

The consecutive records follow a 2010 law that requires foreign banks to report their U.S. account holders to the IRS. If Americans continue to forfeit their citizenship at their current pace, the total for 2017 will set another one, surpassing the 5,411 expatriations in 2016 by about 500, a 10% increase.

The U.S. taxes the assets and income of its citizens, wherever they are. Until the Foreign Account Tax Compliance Act, the U.S. government had trouble collecting taxes from U.S. citizens who live permanently overseas. They could hold on to their U.S. passports but remain out of the reach of the IRS.

Boris Johnson, the British foreign secretary, is typical of those who have been relinquishing their U.S. citizenships in record numbers. Mr. Johnson, whose name was on an IRS list published last year, was born in New York to British parents. The family returned to the U.K. when he was a child, and he has lived there since.

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Mr. Johnson disclosed in 2014 interview with National Public Radio that the IRS had handed him a tax bill for capital gains on the sale of his north London home. Without FATCA, the U.S. government likely would not have known about the sale.

"FATCA is effective because it essentially deputizes the banks to find these people for the IRS," said Ryan Dunn of Andrew Mitchel LLC.

The law was meant to target tax evasion rather than the typical middle income family living in a foreign country, "but in order to catch the big fish, the U.S. created a dragnet that caught even the small fish," Mr. Dunn said.

Banks that fail to comply with the law could be subject to a 30% withholding tax on their U.S. income, Mr. Dunn said.

There had been recent discussions among Ways and Means Committee Republicans about no longer taxing the earned income of U.S. expatriates. Rep. George Holding (R., N.C.), a committee member, had been advocating such a proposal and said recently that he was optimistic about getting it included. Mr. Holding said that when he talks to U.S. multinational companies, that they tend not to hire Americans because it effectively costs more to do.

Republicans also put a repeal of FATCA in their 2016 party platform. But neither provision appears in the tax bill released on Thursday.

Linda Schilcher, a retired professor of Middle Eastern history, was among the more than 1,300 ex-Americans listed in Thursday's IRS report.

Ms. Schilcher lived in California and taught at several American universities before moving to Germany, where she works as a text translator, several years ago. She gave up her passport and took German nationality to live near her children and grandchildren in Europe, she said.

Though she described herself as "American through and through," Ms. Schilcher said she found it "absurd" that U.S. citizens with foreign incomes of less than $100,000 have to declare to the IRS.

Ms. Schilcher said she was tired of having to defend the U.S. "I am not at all impressed with the national and international politics of the U.S. at this time and want no longer to be associated with these," Ms. Schilcher wrote in an email.

U.S. citizens living abroad need to report all income, but if they make less than $100,000, they may be eligible for "foreign earned income exclusion," meaning they don't have to pay U.S. tax, according to Mr. Dunn.

The IRS recorded more than 1,000 expatriations for the first time in 2010, according to Mr. Dunn and tax lawyer Andrew Mitchel, who track the IRS data at their International Tax Blog.

The 1,534 expatriations that year climbed to more than 1,700 in 2011, and then to nearly 3,000 in 2013. By the end of 2016, expatriations had increased 253% since 2010, the data show.

Richard Rubin contributed to this article.

Write to Joe Palazzolo at joe.palazzolo@wsj.com

(END) Dow Jones Newswires

November 02, 2017 18:37 ET (22:37 GMT)