updated 1:56 PM CET, Nov 21, 2019

Questions raised over 'need' for some 'accidentals' to get SS numbers after new IRS 'Relief Procedures' for renouncing

Questions some "accidental Americans" have been expressing about whether they need to acquire a Social Security Number if they are planning to renounce their U.S. citizenship appear to have been answered, at least with respect to those who qualify to renounce under a set of "new procedures" unveiled by the U.S. Internal Revenue Service on Friday.

The answer, at least for those planning to take advantage of the IRS's new program for renunciation – and who qualify to undertake it – is no, it seems you don't.

In announcing its new "Relief Procedures for Certain Former Citizens" on its website, the IRS includes a link to a "Relief Procedures FAQs" page, where the 16th of 23 questions is: "What if I don’t have a Social Security Number (SSN)?"

"If you do not have an SSN, you may still make a submission under these procedures," the IRS answers.

"In this situation, and for purposes of these procedures, leave the boxes blank where an SSN is requested.

"It is not necessary to obtain an SSN merely for the purpose of using these procedures. If you mistakenly applied for and received an ITIN in the past, please include your ITIN on your submission."

Importantly, the IRS response is only for those who are eligible to qualify to renounce under the new Relief Procedures" regime. As reported, this means only those who have relinquished their citizenship since March 18, 2010, or have not yet done so; who have less than US$2m in net worth; and who have never filed U.S. tax returns as U.S. citizens or residents.

Anyone who does not meet these requirements, or who does meet these requirements but has no intention of renouncing under the new Relief Procedures program, is thought to still need to obtain a Social Security Number, also known as a Tax Information Number (TIN), which non-U.S. banks and financial institutions will require in order to comply with the Foreign Account Tax Compliance Act after the end of this year. 

It wasn't immediately known whether this news will prompt the Dutch Banking Association to change the content of an animated video on the home page of its website in which, as reported here two weeks ago, it warns those of its American clients who lack Social Security numbers that they need to get them – if they don’t wish to lose their Dutch bank accounts.

Your bank should provide your SSNIn its video, which may be seen here, and from which the image, left, has been taken, the Nederlandse Vereniging van Banken (NVB) explains clearly, in both English and Dutch, how Americans living in the Netherlands and who lack a Social Security number can apply for one at the U.S. Embassy.

Relief... to a point

The news that accidental Americans in theory don't need to get a U.S. Social Security Number before they renounce is likely to be met with relief – although it may be tempered with concern that there may be some loophole that could catch out the unlucky or unwary renunciant, as many say is often the case when it comes to expatriate Americans and tax issues. 

Editor's note: This story has been updated in response to new developments. To see the follow-up story, click here.