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

What are the Number of LPRs who Leave U.S. Annually without filing Form I-407 – Abandonment?

By · November 29, 2014 · Updated June 3, 2026

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 CitizenshipUSCIS Table of I-407 Abandonments

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
Australia Asian Islands Map


B

Bangladesh
Barbados
Belarus

Belgium
BulgariaEurope Map


C

Canada
China
Cyprus
Czech Republic


D

Denmark


Middle East Map

E

Egypt
Estonia


F

Finland
France


G

GeorgiaAsia Map - including Russia
Germany
Greece


H

Hungary


I

Iceland
India
Indonesia
Ireland
Israel
Italy


J

JamaicaSouth America Map
Japan


K

Kazakhstan
Korea
Kyrgyzstan


L

Latvia
Lithuania
Luxembourg


M

MaltaCentral America Map
Mexico
Moldova

Morocco


N

Netherlands
New Zealand
Norway


O


P

Pakistan
Philippines
Poland
Portugal


Q


R

Romania
Russia


S

Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland


T

Tajikistan
Thailand

Trinidad
Tunisia
Turkey
Turkmenistan


U

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


V

Venezuela


 

 

 

 

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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