How many former U.S. citizens and long-term lawful permanent residents have filed (or will file) IRS Form 8854?
How many former U.S. citizens and long-term lawful permanent residents have filed (or will file) IRS Form 8854?
Can this information be obtained directly from the IRS through a Freedom of Information Act (“FOIA”) request?
See, Does IRS Notice 2009-85 regarding expatriation have the “force of law”? Posted April 14, 2014.
Unfortunately, the law has left much confusion for USCs and LPRs living overseas who have –
- “relinquished” their citizenship many years ago (in the case of USCs), or
- terminated U.S. income tax residency by application of a U.S. income tax treaty (in the case of LPRs).
See, Why Section 7701(a)(50) is so important for those who “relinquished” citizenship years ago (without a CLN)
See, Countries with U.S. Income Tax Treaties & Lawful Permanent Residents (“Oops – Did I Expatriate”?)
The one certainty under the law, is that any former USC or LPR, regardless of their wealth or income, will necessarily be a “covered expatriate” if they do not file IRS Form 8854 and meet the certification requirements under the law.
This begs the question: how many have filed IRS Form 8854?
See, Revisiting the consequences of becoming a “covered expatriate” for failing to comply with Section 877(a)(2)(C). (Posted on April 16, 2014)
May 15, 2014 at 6:17 pm
[…] A word of caution – Do not be lulled in to thinking that by “relinquishment” you have escaped the federal tax consequences of Sections 877, 877A, 2801, 7701(a)(50), et. seq. See, Why Section 7701(a)(50) is so important for those who “relinquished” citizenship years ago (without a CLN)] See also, How many former U.S. citizens and long-term lawful permanent residents have filed (or will file) IRS…] […]