Tax Compliance

How Many of the 5,211 Former U.S. Citizens (who Renounced in 2014 and 2015) are Still U.S. Taxpayers?

By · August 23, 2015 · Updated June 3, 2026

CORRECTION TO THIS POST:  If you renounced your U.S. citizenship, you may think you cease to be a U.S. taxpayer.  This depends upon when the termination of citizenship occurred.

More posts will follow addressing these issues.

Unfortunately, the law is not that simple, regardless of your wealth, income, assets or future inheritances or gifts.IRS Form 8854 Part IV- Including Certification

The way the federal tax law works, is that the U.S. “expatriation tax law” applies to the poorest former U.S. citizen (and certain long-term LPRs), wherever they reside if they do not comply with the certification requirements of Section 877(a)(2)(C). See, Why “covered expat” (“covered expatriate”) status matters, even if you have no assets! The “Forever Taint”!

The law continues to obligate certain former U.S. citizens to be subject to the U.S. taxation laws on a worldwide bases, unless and until they notify the IRS and certify under penalty of perjury.  This depends upon the time of the renunciation.

Patrick W. Martin

Patrick W. Martin

U.S. International Tax Lawyer · Shareholder, Chamberlain Hrdlicka

Patrick W. Martin is a U.S. tax lawyer licensed in California, Texas, and Washington, D.C., with 32+ years advising on the tax consequences of renouncing U.S. citizenship or abandoning lawful permanent residency. He served as lead counsel in Aroeste v. United States, the landmark federal case on green card holders, tax treaties, and the exit tax. Best Lawyers in America® (Tax Law), 2015–2025.

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