renouncing citizenship
WSJ Asks the Question: Is the IRS Undercounting Americans Renouncing U.S. Citizenship?
Is the IRS Undercounting Americans Renouncing U.S. Citizenship?, posted Sept. 16, 2015.
The names of U.S. citizens who have renounced is published quarterly pursuant to IRC Section 
6039G. See, prior related posts: 1,426 Individuals Give Up Passport: Record Number of U.S. Citizens Renouncing: Quarter 3 for 2015, October 30, 2015.
No one knows for certain if the IRS (including the IRS per some of my conversations) is getting complete data from the Department of State regarding each name and individual.
The graph I have prepared shows the number of names reported quarterly as I track all reported names quarterly that related to clients and non-clients. The latest cumulative amounts for 2015 (which does not include the 4th quarter) shows 3,221 thus far in the year. If there is close to 1,400 as was the case for the last quarter, the total will be a record – by a bunch; i.e., close to 5,000 renunciations for the year.
Anecdotally, I have seen renunciations surge in our practice, largely as U.S. citizens residing around the world (typically in the “Accidental American” category) learn about the long arm of the U.S. tax law by way of their local financial institutions and reporting and documents requested as part of FATCA. See, Why Most U.S. Citizens Residing Overseas Haven’t a Clue about the Labyrinth of U.S. Taxation and Bank and Financial Reporting of Worldwide Income and Assets, posted Nov. 2, 2015.
None of this answers the question of whether there is under-reporting of the names? Indeed, the question will likely not be answered without more information provided by the U.S. Department of State and the U.S. Treasury (i.e., the IRS officers responsible for issuing the names and report in the Federal Register).
The government is also likely to reject issuing information on these details to individuals and their advisers as part of a Freedom of Information Act (“FOIA”) request. I have had similar requests rejected by the government under the so called “Exemption 7(E)” of FOIA. See,
“Expatriation” Implies Leaving the U.S., But Many More Want to Come to the U.S.: Tax Consequences
U.S. citizens and long-term residents who are considering renouncing their citizenship or abandoning their lawful permanent residency (“LPR”) are increasingly undertaking more sophisticated life and tax planning before “taking the plunge”!
Many (in my experience – all) of these “expatriates” eventually want to be able to visit the U.S. and in some cases possibly come back to live permanently. Many simply apply for and obtain a B1/B2 visa.
To appreciate how many more persons want to immigrate to the U.S. compared to emmigrate from it, see an earlier post: The Number of Citizens Leaving (Renouncing) Versus Coming (Naturalizing) is Just a Speck
This is the other “side of the coin” so to speak, since individuals contemplating coming to the U.S. often should undertake pre-immigration tax planning. One means for non-U.S. citizens to become LPRs and eventually U.S. citizens, is through the EB-5 visa program.
Immigration attorney Ms. Teodora Purcell has written prior guest posts, including: When is the loss of US nationality effective? [Guest Post from Immigration Lawyer]
The next post on this site will be a complete article by Ms. Teodora Purcell explaining in more detail the EB-5 visa program and recent developments.
As to the tax implications of immigration to the U.S. (as opposed to emigration from it), I wrote the tax chapter in the latest edition of the American Immigration Lawyers Association (“AILA’s) treatise – Immigration Options for Investors & Entrepreneurs US$199.
That treatise is heavily focused on “EB-5 investors” and the tax discussion is titled: Key U.S. Tax Considerations for EB-5 (& Other) Visa Applicants.
Ms. Teodora Purcell’s contact information is set out below:
Teodora Purcell | Attorney at Law
FRAGOMAN
11238 El Camino Real, Suite 100, San Diego, CA 92130, USA
Direct: +1 (858) 793-1600 ext. 52424 | Fax: +1 (858) 793-1600
TPurcell@Fragomen.com