Although 2020 is still set to be the peak year for U.S. citizenship renunciations, the latest list of quarterly renunciants' names – published yesterday – contains fewer than a third of the numbers published in both the first and second quarters of this year.
While experts have long cautioned against reading too much into the numbers in any given quarter, most observers think that the fact that only 732 names were on the latest list, covering the three months to the end of September, reflects the inability of those who would like to renounce to make appointments or otherwise go through with the process, as a result of the closure of the relevant U.S. consulary offices in the countries in which they now live.
Evidence that the latest list, like the one before it, is at least in some part if not entirely comprised of a backlog of names that has built up in previous quarters is evident in the fact that at least one person known to the American Expat Financial News Journal saw his name on the current list, after having formally renounced his citizenship in February, 2019.
Said this former American, who now lives in Europe: "I renounced on Valentine's Day in 2019, but my doxing didn't happen until Halloween 2020."
("Doxing", also written "doxxing", is a popular expression among some American renunciants and would-be renunciants, as it suggests one's personal information is being published without their permission, which is what some regard the government's publishing of renunciants' names as an example of.)
Another American now resident in Europe, who formally renounced her citizenship "in early December 2018," told the American Expat Financial News Journal today that she still has yet to see her name on the list, which is formally known as the "Quarterly Publication of Individuals, Who Have Chosen To Expatriate, as Required by Section 6039G".
As reported here in July, citizenship renunciations are understood to be at a near stand-still globally, even though demand is said to be high, particularly among so-called "accidental Americans", many of whom are struggling to maintain bank accounts in the countries they have lived in most if not all of their lives, and are citizens of.
This is because the fact that they were born in the U.S., or had one or more American parents, makes them considered to be American by the banks, but often they were unaware of this fact until the banks informed them, and are reluctant to obtain the "Taxpayer Identification Number", usually a Social Security number, that the banks say they need in order to comply with a relatively recent U.S. tax evasion law known as FATCA.
As reported here last week, the founder and president of the Paris-based Association des Américains Accidentels (Accidental Americans Association, or AAA) recently made a formal request to the U.S. Ambassador to France that the U.S. "re-open the renunciation services and the FBU (Federal Benefits Unit)" in France, so that accidental Americans resident in that country could begin the process of "expatriating", in order to be able to keep their bank accounts.
Fabien Lehagre noted that the problem of accidental Americans unable to even begin the process of renouncing their U.S. citizenships, in order to be able to retain their bank accounts in the countries they are citizens of, and currently live in, is the situation "in many countries" as a result of the Covid-19 pandemic, not only in France.
Another is the UK, where a statement on the U.S. Embassy's website states that "the U.S. Embassy in London, Consulate General Edinburgh, and Consulate General Belfast are currently unable to accept appointments for Loss of Nationality applications. Under guidance from the U.S. Department of State, we are currently unable to process Loss of Nationality applications, and cannot provide a timeframe for when this service will resume.
"We recommend that you periodically check this website for updates on resumption of this service. Please do not email documents or send by mail until normal services resume."
Meanwhile, no doubt reflecting the frustration growing numbers of accidental Americans and expats have been feeling, their issues hae been getting considerable mainstream media coverage recently, including on the websites of such publications as the Washington Post and the Wall Street Journal, as well as in the foreign press, such as NRC Handelsblad (www.nrc.nl), one of the Netherlands' established mainstream media groups.
Quoting the IRS, that Wall Street Journal article noted that of the 2,907 names that were published on the Federal Register for the first quarter of 2020, "only three actually expatriated this year".
"Of the remainder, 941 expatriated in 2019, 441 in 2018, 736 in 2015 and 713 in 2014.
"An additional 76 were sprinkled across other years."
It should be noted that in addition to containing the names of U.S. citizens "who have chosen to expatriate" the Federal Register's list also contains the names of "long-term residents – so-called Green Card holders – who are seeking to end their U.S.-resident status, for tax reasons. Because such Green Card holders are able to proceed with their relinquishments by mail, and therefore not need to meet with consular officials in person, some observers think they could account for a disproportionate share of the names on the 2020 lists. There is, however, no way to know to what extent this is the case.
To see the latest list of renunciants' names on the Federal Register's website, click here.
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