Tax Compliance

Will the IRS simply select the list of published former citizens for tax audits?

By · June 12, 2014 · Updated June 3, 2026

Will the IRS simply select the list of published former citizens for audits? It is a simple process for them to cross reference the names that are published.

The complete set of lists going back to the mid-1990s can be reviewed here.  Quarterly Publications.

The IRS does not have to wait for IRS Form 8854 to be filed by the former USC.

See an earlier post regarding IRS CI activity in this area: This is a bit of a Bombshell – If the IRS Criminal Investigation (“CI”) is investigating U.S. citizens renouncing their citizenship?

A later post will discuss methods by which the IRS may be identifying long-term lawful permanent residents (LPRs) who have formally (or informally – by operation of law) abandoned their LPR status for tax purposes.  The list of LPRs is NOT provided in the quarterly publications list that list USCs;  and it is not as simple of a process for the selection and identification of LPR taxpayers for audits, reviews and investigations by the IRS.

 

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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