Much has been made about the number of citizens who have been renouncing their U.S. citizenship over the last few years.  In historical terms, it is a relative explosion.  See, earlier post – The 2014 Third Quarter Renunciations Is probably the New Norm –

However, compared to the number of lawful permanent residents (LPR) who are leaving the U.S., the number is relatively small.  See, earlier post  The Number of LPRs “Leaving” the U.S. is 16X Greater than the Number of U.S. Citizens Renouncing Citizenship

On a related post, the question was raised –What are the Number of LPRs who Leave U.S. Annually without filing Form I-407 – Abandonment?

However, the number of individuals who wish to come to the U.S. to become citizens is far in excess of the number who are renouncing their citizenship.  According to the USCIS, there are about 700,000 individuals annually who become naturalized citizens.  In the year 2008, there were more than 1 million naturalized citizens.  See table:

Compare these numbers to just about 3,000 annually of individual who are renouncing their citizenship.

Of course, everyone has their own story and reasons for either coming or going, but in relative terms, those who find it desirous to renounce citizenship (at least in absolute numbers and relative terms) represent a small speck (less than 1/2 of 1 percent), compared to those who are becoming naturalized citizens.

Finally, for anyone who wishes to become a naturalized citizen, they must be aware they cannot “reverse” the decision without having potentially adverse U.S. tax consequences.  See, Why a Naturalized Citizen cannot avoid “Covered Expatriate” status under IRC Section 877A(g)(1)(B)

A prior post identified the number of lawful permanent residents (LPRs) who file Form I-407 to formally abandon their lawful permanent residency.  See,  The Number of LPRs “Leaving” the U.S. is 16X Greater than the Number of U.S. Citizens Renouncing Citizenship

These numbers of I-407 forms filed annually were obtained through a freedom of Information Act (“FOIA”) request and provided by the USCIS.  See tabl:

Of course, this statistic does NOT identify the number of the approximate 13.3+ million LPRs who leave the U.S. to live elsewhere in another country without completing Form I-407 and formally abandoning.  The estimated number of LPRs was 13.3 million for the year 2012 as reported by the Office of Statistics of the DHS. See, Estimates of the Legal Permanent Resident Population in 2012.

Maybe the number of individuals who fall into this latter category (i.e., moving out of the U.S. without filing Form I-407) is several hundred of thousands of individuals annually?

Importantly, from a taxation perspective, anyone who moves and lives in a country with a U.S. income tax treaty (the list of these countries is set out below – from the IRS website), needs to be careful not to be deemed to be a “covered expatriate” due to the application of IRS Form 7701(b)(6).  See, IRS Notice 2009-85.

See, the following posts with further explanation of the tax law for LPRs who move and live in one of the countries listed below.  Countries with U.S. Income Tax Treaties & Lawful Permanent Residents (“Oops – Did I Expatriate”?)

See also, Who is a “long-term” lawful permanent resident (“LPR”) and why does it matter?

Becoming a “covered expatriate” has U.S. tax consequences not just to the “former long-term LPR”, but also to their family and friends who are “U.S. persons” (as defined under Section 7701.  See, The “Hidden Tax” of Expatriation – Section 2801 and its “Forever Taint.”

A

Armenia
Australia
Austria
Azerbaijan

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B

Bangladesh
Barbados
Belarus
Belgium
Bulgaria

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C

Canada
China
Cyprus
Czech Republic

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D

Denmark

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E

Egypt
Estonia

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F

Finland
France

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G

Georgia
Germany
Greece

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H

Hungary

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I

Iceland
India
Indonesia
Ireland
Israel
Italy

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J

Jamaica
Japan

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K

Kazakhstan
Korea
Kyrgyzstan

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L

Latvia
Lithuania
Luxembourg

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M

Malta
Mexico
Moldova
Morocco

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N

Netherlands
New Zealand
Norway

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O

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P

Pakistan
Philippines
Poland
Portugal

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Q

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R

Romania
Russia

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S

Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland

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T

Tajikistan
Thailand
Trinidad
Tunisia
Turkey
Turkmenistan

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U

Ukraine
Union of Soviet Socialist Republics (USSR)
United Kingdom
United States Model
Uzbekistan

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V

Venezuela

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The focus of Tax-Expatriation is to discuss legal matters of U.S. citizenship renunciation-relinquishment and lawful permanent residency abandonment.

There have been a great deal of resources discussing the number of USCs residing outside the U.S. and those who ultimately renounce citizenship.

See prior posts related to this topic –

The 2014 Third Quarter Renunciations Is probably the New Norm –

Wow, the number of 2,999 U.S. citizens who renounced in the year 2013 shattered the prior record set in 2011 of 1,782 renunciations. Why so many renunciations?

The List is Out – and Its 1,001 Former U.S. Citizens for the 1st Quarter 2014

There has not been any detailed discussion of the number of LPRs who leave the U.S. annually.  The data provided by the U.S. Citizenship and Immigration Services reflects about 16 times more LPRs formally abandon their lawful permanent residency status by filing Form I-407 compared to U.S. citizens who renounce. The chart here shows a comparison for the years 2000 through 2013 of the total (i) USCs who have renounced compared to (ii) LPRs who have formally abandoned that status.

Note that for the year 2013, it is only through May 2013, so the total abandoned for the entire calendar year 2013 could well exceed 20,000.

Of course, this statistic does NOT identify the number of total current 13.3+ million LPRs who leave the U.S. to live elsewhere in another country without completing Form I-407 and formally abandoning.  The estimated number of LPRs was 13.3 million for the year 2012 as reported by the Office of Statistics of the DHS. See, Estimates of the Legal Permanent Resident Population in 2012

See also  The Foreign-Born Population of the United States: Multi-National Families and “Tax Expatriation”