[Ed. – See emphasis: people are renouncing citizenship to escape a broad range of tax AND non-tax financial consequences, due to FATCA.]
For all the immigrant arrivals the trickle the other direction is increasing. The number is still small, with the “published” expatriates for the quarter was 630 for the last quarter or 2013.
That brings the total number to 2,999 for all of 2013. The previous record high for a year was 1,781 set in 2011. It’s a 221% increase over the 932 who left in 2012. You can call it a shaming or a public record, but the Treasury Department is required to publish a quarterly list of Americans who renounced their U.S. Citizenship or terminated their long-term U.S. residency. The public outing puts Americans on notice who relinquished their rights.
Those seem like tiny numbers, yet the total thus far for 2013 is 2,369. See Number of Taxpayers Who Renounced U.S. Citizenship Skyrockets to All-Time Record High, quoting Andrew Mitchel. Under U.S. tax law, it is not relevant why someone expatriates. Whether the expatriation was motivated by tax avoidance or something else used to matter, but the law was changed in 2004.
Since then, the tax and other consequences do not depend on why one leaves. Yet after Facebook co-founder Eduardo Saverin departed permanently for Singapore with his Facebook IPO riches, there was an angry backlash. Mr. Saverin’s post-Facebook fly-away prompted such outrage that Senators Chuck Schumer and Bob Casey introduced a bill to double the exit tax to 30% for anyone leaving the U.S. for tax reasons. …
Moreover, the annual foreign bank account reports known as FBAR forms carry civil and criminal penalties all out of proportion to tax violations. The penalties for failure to file these forms, civil and criminal, are severe. Even civil penalties can quickly consume the balance of an account.
The coup de grace is FATCA, which is ramping up now worldwide. It requires an annual Form 8938 to be filed with income tax returns for foreign assets meeting a threshold. And foreign banks are sufficiently worried about keeping the IRS happy that many simply do not want American account holders. Americans abroad can be pariahs shunned by banks for daily banking activities.
Even Canada has now agreed to turn over data to the U.S., though many in Canada are hopping mad about it. See Canada Signs U.S. FATCA Deal, IRS To Get Data. Still, leaving America can have a special tax cost.