Not very many people expatriate. Their names are published publicly each quarter. Below is the link that has the name for those expatriating during the third quarter of 2009.

Executive Summary – Not very many people expatriate. Their names are published publicly each quarter. Below is the link that has the name for those expatriating during the third quarter of 2009. There were approximately 120 such people who did file for expatriation in the third quarter of 2009. If we multiply that by four we get about 500 people a year. This is low when one considers hundreds of thousands of expatriates leave the USA every year, some say the numbers are in the millions. Some may go back to visit many never return.

The link to see the names of those expatriating is here:

http://www.thefederalregister.com/d.p/2009-11-19-E9-27751

Expatriates Returning Home – A common question is whether or not an expatriate can return back to the USA after they expatriate. To file expatriation one must show the USA their new passport from another country so the USA 100% has a trail from the old you to the new you. Will they let you return for visits? Hard to say. We think overwhelming no.

If you can obtain a passport allowing visa free travel into the USA then the chances of being allowed in as a tourist would be higher especially if one tried to do a land crossing from Canada or Mexico. The point to consider is the USA doesn’t want to let people expatriate and then start spending time in the USA as if nothing changed except now they do not pay taxes.

Many years ago one did not have to pay any exit tax to the USA and they did not impute tax return obligations on the expatriate for ten years. All one needed to do was ask for expatriation in a simple direct manner. We had a client who did this and then got a passport allowing for visa free travel in and out of the USA. He said he had no trouble going in and out on business. But he was under an older program and that was when everyone was trying to get into the USA not out, so the USA did not concern itself with expatriation. If they opened up such a program today I expect there would soon be an 18-month waiting list of people applying to cancel their citizenships and leave with no need to file any tax returns anymore.

Can The USA Turn Down Your Expatriation – Yes they can. They will audit your old tax returns and may say you owe them more money. They can dispute the expatriation tax figure you arrived at and ask for more money. If you do not pay them what they unilaterally ask for then they deny the application for expatriation and one could assume begin vigorous collection action on any moneys they think you owe them.

Do Other Countries Tax People Who Wish To Renounce Their Citizenship – None that we know of.

Can You Convince the USA to Cancel Your Citizenship – There are provisions in the law for this but we just never see them do it. The last remaining asset the USA has is the taxpaying citizen.

Do You Think This Will Change Anytime Soon – We think the USA will any day now impose exit visa restrictions on those wishing to leave the USA. They may not let you go if they think you do not have sufficient roots to cause you to return. Expatriation will just be on the books and not worth anything. To expatriate you need a second citizenship. If you cannot leave how can you get a second citizenship. Those fortunate enough to already have a second citizenship could still try to expatriate.

What About Second Citizenships and Passports – We think the USA will forbid the acquisition of second citizenships and passports any day now. Those that have them will be grandfathered in providing you advise them of the second citizenships. This of course will enable them to track you effectively, which many people specifically are trying to avoid.

What Do We Suggest – We suggest leaving while it is still possible. Any way you leave is up to you but leave while you still can.

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