More duplicate names spotted in Q4, but 2022 was still 6th largest year ever for renunciations

That is, unless, as the American Expat Financial News Journal has been exclusively reporting since November 2021, the number of names on the latest list that have appeared on previous lists is taken into account, in which case the 2022 total is reduced by 386, to 3,429.

This is still the sixth largest annual number of renunciants' names ever to be published on the Federal Register site since the numbers began to increase after 2010, when the Foreign Account Tax Compliance Act (FATCA) was signed into law by President Obama.

Even before FATCA began to come into force in 2014, American expats everywhere began to encounter problems keeping their non-U.S. bank and financial accounts, in addition to other added costs, hassles and potential financial risks that have now come to be associated with remaining U.S. tax-compliant while abroad.

As previously, the 2022 list with its year-ending total number of renunciants is expected to be seen as further evidence of this trend.

The AXFNJ was assisted in analyzing the latest Federal Register data – and specifically, in helping us to identify those names that had already appeared on previous lists, to ensure they didn't get counted again – by a Europe-based data expert, who has requested to be identified only as being part of the AXFNJ editorial team.

This data expert has helped us previously in spotting the phenomenon of names being published more than once, beginning in November, 2021.

(In fact, the name duplications are believed to date back further, and a 2014 article on the GlobalNews.ca website, with the headline "U.S. list of ex-citizens full of errors, duplication," referred to numerous errors and discrepancies, which others have also spotted over the years, between the renunciation data produced by the U.S. Treasury and that produced by the FBI.)

This article goes on to note that "in 2010, an ex-citizen’s surname was listed as “Vice Consul” while on the Q4 2013 list, there's a name that's described as appearing to be "part of a residential address in Switzerland."

Importance of Fed
Register 'doxing' list

Because the U.S. government doesn't formally publish expatriation/citizenship renunciation data, those interested in monitoring U.S. citizenship renunciations have taken to visiting a specific page of the Federal Register website the four times a year when the next "Quarterly Publication of Individuals, Who Have Chosen To Expatriate," as the list is called, is due to appear.

According to the list that went live on Friday, the fourth quarter of 2022 saw 979 new names listed, and 45 that had appeared previously (see tables above and below).

In 2022, the percentage of names that that had appeared on previous Federal Register "doxing" lists was roughly 10% of the total (386 out of 3,815).

("Doxing" is a slang term that's usually defined as the act of having one’s personal information publicly revealed, typically in an online context, which some expats have taken to using in reference to the Federal Register's lists, which were introduced in the 1990s in an effort to discourage others from renouncing).

U.S. Treasury officials didn't respond to a request for comment, or to a request to know whether the Federal Register data is consistent with the U.S. government's own official numbers. A spokesperson for the State Department said it had "no further comment beyond what is publicly available on the Federal Register."

Some predict drop-off in Q1

Looking ahead to 2023, meanwhile, many Federal Register list-watchers say they're confident that the quarterly renunciation numbers will drop off sharply, beginning in the first quarter of this year, in anticipation of a possible and significant reduction in the fee the U.S. charges those seeking to expatriate.

As reported, the U.S. State Department announced earlier this month its "intent" to reduce the fee it charges those seeking to renounce their citizenships to US$450, from its current US$2,350, ahead of a hearing scheduled for the following Monday, when a U.S. district court judge in Washington, DC had been scheduled to hear oral arguments in a long-running challenge over the U.S. government's citizenship renunciation regime, including its fee.

The case had been brought by the Paris-based Association of Accidental Americans, in partnership with some 13 "accidental American" co-plaintiffs from around the world.

However, Toronto-based citizenship lawyer John Richardson says he doesn't believe the possibility of a drop in the fee will see a significant, or indeed any, reduction in the numbers of those seeking to renounce ahead of this predicted price-drop at all – and not only because the names on the list are comprised of so many names of people who renounced quarters and even years earlier.

"Most of my clients are proceeding with their renunciation plans regardless," says Richardson, who helps American expats around the world to navigate the renunciation paperwork.

Questions regarding Federal
Register names list not new

As the AXFNJ and other news organizations have said previously – as have many citizenship experts – the Federal Register's quarterly list of renunciants' names has long been considered imperfect, even before the fact that many of the names on it had appeared previously became well known.

Perhaps most apparent, especially to those who have actually gone through the renunciation process, is the fact that although the Federal Register says its list contains “the name of each individual losing United States citizenship…with respect to whom the Secretary [of the Treasury] received information during the [most recently-ended] quarter,” it's been obvious for years that some, if not many, of those named had actually lost their citizenship a year or more before the quarter in which their name appeared.

(Tweeted one expat on Sunday evening, with a link to the latest Federal Register list of renunciants' names: "Renounced Sept 2019 still not on the freedom list...At least I have my certified CLN [Certificate of Loss of Nationality] to prove I am no longer a US citizen.")

Whether or not the names of Green Card holders who give up their Green Cards are included on the Federal Register’s quarterly lists is, meanwhile, a matter of some debate, even though the introduction to this list says that it does. Green Card holders aren't technically U.S. citizens but citizens of other countries who have been given “long-term resident” tax status in the U.S., which normally means they're required to formally apply to be released from this.

To see the most recent quarterly list of names of Americans who have formally expatriated on the Federal Register website, click here.

To see the numbers of Americans who have expatriated since 2009, as well as a breakdown of the numbers of duplicate names found in the 2022 data, scroll down...