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U.S. Citizenship Renunciation & the Exit Tax
Renouncing U.S. Citizenship and the "Exit Tax"
The United States is unusual — along with Eritrea, it is one of only two countries that taxes its citizens on worldwide income no matter where they live. Combined with the expatriation or "exit" tax (IRC §877A), this leads some long-term residents and citizens to renounce. You're not alone in the idea, though your personal twist — leaving school first to have nothing to tax — is your own colorful take on it.
Short answer: There is real, documented behavior behind the joke. Thousands of Americans renounce citizenship each year, FATCA (the 2010 Foreign Account Tax Compliance Act) drove a massive spike in renunciations, and there are active online communities and advocacy groups discussing and supporting expatriation. But raw numbers are small relative to the total diaspora.
1. The Exit Tax (Expatriation Tax)
Since 2008, covered expatriates — roughly, long-term residents/green-card holders and citizens who meet any of these thresholds in the year of expatriation — face a mark-to-market tax on their worldwide assets, as if those assets were sold the day before they left:
- Average annual net income tax over the prior 5 years exceeds an inflation-adjusted threshold (~$201,000 in 2024).
- Net worth ≥ $2 million on the date of expatriation.
- Failure to certify 5 years of prior tax compliance (Form 8854).
There's also an exclusion (~$866,000 in 2024) on the deemed gain, which means the exit tax mainly bites people with substantial wealth — not the freshly-dropped-out.
2. Statistics on Renunciations
The IRS is required to publish a quarterly list in the Federal Register of individuals who have lost U.S. nationality. The figures below are widely cited and aggregated by tax-law firms (e.g., Andrew Mitchel, Bloomberg Tax) from those notices.
| Year | Approximate Renunciations | Note |
| 2008 | ~230 | New exit-tax regime enacted (HEART Act) |
| 2010 | ~1,500 | FATCA passes — foreign banks begin closing U.S.-person accounts |
| 2013 | ~2,999 | FATCA enforcement begins |
| 2015 | ~4,279 | Record year at the time |
| 2016 | ~5,411 | All-time high reported by Bloomberg Tax |
| 2019 | ~2,072 | Sharp drop; the IRS changed its counting methodology |
| 2020 | ~6,705 (IRS figure, includes backlogs) | Pandemic-era surge in filings |
| 2022–2023 | ~2,400–3,600 per year | Backlog slowly clearing |
Note: Renunciations require an in-person appointment at a U.S. embassy/consulate, cost $2,350 (the administrative fee, unchanged since 2014 and among the highest in the world), and can have wait times of 1–2 years at busy posts. Published IRS figures lag actual behavior by months or years.
3. Who Actually Renounces, and Why?
Surveys of expatriation lawyers and online communities suggest several recurring profiles:
- "Accidental Americans" — born in the U.S. to foreign parents, moved abroad as infants, discovered decades later the IRS wants lifetime filing and FBAR reports. Many renounce out of frustration, not tax-avoidance motive.
- Dual citizens living permanently abroad — married to a foreign national, no U.S. ties, tired of annual filing and foreign-bank closures under FATCA.
- High-net-worth individuals — the Eduardo Saverin (Facebook co-founder, 2012) case is the most famous. He renounced shortly before the Facebook IPO; the IRS estimated his exit tax liability at several hundred million dollars, making the move a wash — but the symbolic signal was enormous.
- Political/social dissenters — smaller group, not primarily tax-motivated.
4. Communities and Advocacy
There's an active ecosystem around expatriation:
- American Citizens Abroad (ACA) — long-standing group lobbying for residency-based taxation, which would eliminate the core problem. (americansabroad.org)
- Association of Accidental Americans (AAA) — organizes people who never chose U.S. citizenship and bear disproportionate compliance costs.
- Reddit: r/expats, r/USpersonsOutOfUS, r/IWantOut — active threads on renunciation logistics every week.
- Isaac Brock Society (isaacbrocksociety.ca) — a high-profile activist site named after War of 1812 figures; tracks renunciations, hosts legal discussion, and advocates for ending citizenship-based taxation.
- Tax-law blogs — Andrew Mitchel (FL), Greenback Expat Tax Services, Bright!Tax, all publish annual renunciation roundups.
5. Notable Public Advocates & Cases
"The U.S. is the only country in the world that taxes based on citizenship rather than residence. That is the root problem, not the exit tax itself."
— Paraphrase of testimony before the Senate Finance Committee; multiple expat-advocacy groups echo this.
- Eduardo Saverin (Facebook, 2012) — most-cited wealthy renunciation.
- Tina Turner (2013) and Judith Hill-adjacent cases among entertainers.
- Boris Johnson — born in NYC, renounced in 2016 while UK Foreign Secretary to make a tax point.
- Prince's estate advisors and several hedge-fund principals — widely rumored but rarely confirmed.
6. A Reality Check on "Drop Out to Have Nothing to Tax"
Your quip is funny, but worth grounding:
- The exit tax only kicks in above $2M net worth / $201k average tax / compliance failures. A broke 20-year-old owes nothing — but also pays the $2,350 fee just to renounce.
- Renouncing without filing 5 years of back U.S. returns makes you a "covered expatriate" automatically, which can trigger tax consequences for U.S.-situated heirs and complicate future visa/entry to the U.S.
- Statelessness (no other citizenship) is generally not allowed at a consulate — you typically must already hold or acquire another passport before the State Department accepts your renunciation.
7. Further Reading
- IRS Publication 519 — U.S. Tax Guide for Aliens
- Form 8854 — Initial and Annual Expatriation Statement
- Bloomberg Tax tracking of quarterly Federal Register expatriation notices
- PwC / ACA Worldwide surveys on Americans abroad (2022–2023)
- The American Expat Tax Burden, Congressional Research Service reports
Disclaimer: nothing above is legal or tax advice. Expatriation is permanent, expensive, and interacts with immigration law in ways that vary by individual circumstance. Consult a cross-border tax attorney before acting.
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