Certification Requirement of Section 877(a)(2)(C)

More renounce US citizenship but deny stereotype

By · April 27, 2014 · Updated June 20, 2026

This article is quite consistent with the many multinational families I have come across in my practice and even person life. The article can be reviewed in its entirety here at More renounce US citizenship but deny stereotype. 

The press and certainly Congress focuses on the handful of wealthy individuals who renounced citizenship to pay less U.S. income, estate and gift taxes.  Little focus has been on the millions of middle income or even low income individuals who live around the world and are caught up in the complex U.S. tax (estate, income, gift and inheritance tax and reporting) and bank account reporting legal web.

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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