IRS From 8854
How Many of the 5,211 Former U.S. Citizens (who Renounced in 2014 and 2015) are Still U.S. Taxpayers?
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.
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.