Quarterly Expatriation Report

Introduction

The Internal Revenue Service (IRS) of the United States releases quarterly reports tracking the number of expatriated citizens processed in the previous three-month period. The reports are announced via the Federal Register which is the primary publication medium of the federal government and used by a number of agencies as an outreach arm to the public.

Ostensibly, the tax bureau maintains these records instead of Citizenship and Immigration Services (CIS) because the IRS uses that information to adjudicate decisions regarding those expatriating citizens upon whom the Expatriation Tax is levied.

An expatriate must meet any one of the following criteria to be liable for the eponymous tax:

  • Average annual net income tax for the five years ending before the date of expatriation or termination of residency is more than a specified amount that is adjusted for inflation ($151,000 for 2012, $155,000 for 2013, $157,000 for 2014, and $160,000 for 2015).
  • Net worth is $2 million or more on the date of expatriation or termination of residency.
  • Failure to certify on Form 8854 that the citizen has complied with all U.S. federal tax obligations for the five years preceding the date of expatriation or termination of residency.

IRS Form 8854 available at is a statement which confirms that up to the date of your expatriation, you have complied with United States Federal Tax Code to the letter of the law. Failing to correctly complete this document means that you are obligated to pay the Expatriation Tax, even if you do not meet either of the previous criteria.

Each year more than 700 thousand people become U.S. citizens in a process called naturalization.

The number of people who pledge allegiance to the United States has been relatively stable over the years.

What is interesting however is the number of individuals rolling back their commitment to the country.

Data is published quarterly by the U.S. Federal Register and each report even discloses the names of expatriating individuals. The latest report published on May 10, 2017, for example, contains the last, first, and middle names of 1,313 individuals losing United States citizenship from whom the government received information during the quarter ending March 31, 2017.

The IRS legal rationale of disclosing the names under the auspices of HIPAA which is supposed to protect patient privacy seems rather strange to an uninitiated observer but it is of out of scope for this article.

After removing duplicate names which are most likely associated with different social security numbers in the back-end systems and calculating a rolling annual total to smooth out variance, the trend becomes more apparent. More people are leaving the U.S. than in previous years.

SELECT date_format(time+365*24*60*60000, 'yyyy') AS "Year",
  count(value) AS "Total"
FROM "us-expatriate-counter"
  WHERE entity = 'us.irs' AND datetime < '2017-04-01T00:00:00Z'
GROUP BY period(1 YEAR, END_TIME)
  ORDER BY time

Expatriated Citizens & Long-term Permanent Residents, 12-month rolling sum

Year Total Change, %
2000 184 -
2001 470 155
2002 373 -21
2003 507 36
2004 545 7
2005 645 18
2006 724 12
2007 285 -61
2008 485 70
2009 174 -64
2010 853 390
2011 1850 117
2012 1742 -6
2013 1151 -34
2014 3319 188
2015 3743 13
2016 4096 9
2017 5557 36

12-month rolling sum. For example, Year 2017 covers the period between April 1, 2016 and March 31, 2017.

Given that it usually takes several months between the submission of an application and the appearance of a name on the list, it is not clear if there is any effect of the latest political season on the expatriation numbers.

The next report is due in early August. Stay tuned!

Expatriated Citizens & Long-term Permanent Residents, Quarterly Totals

SELECT date_format(time+90*24*60*60000, 'yyyy-MMM') AS "Date",
  count(value) AS "Quarterly Total"
FROM "us-expatriate-counter"
  WHERE entity = 'us.irs' AND datetime >= '2010-01-01T00:00:00Z'
GROUP BY period(1 QUARTER)
  ORDER BY time
Date Quarterly Total
2010-Apr 179
2010-Jun 557
2010-Sep 397
2010-Dec 398
2011-Apr 498
2011-Jun 519
2011-Sep 403
2011-Dec 360
2012-Mar 460
2012-Jun 189
2012-Sep 238
2012-Dec 45
2013-Apr 679
2013-Jun 1129
2013-Sep 560
2013-Dec 631
2014-Apr 999
2014-Jun 576
2014-Sep 775
2014-Dec 1061
2015-Apr 1331
2015-Jun 459
2015-Sep 1426
2015-Dec 1057
2016-Mar 1154
2016-Jun 506
2016-Sep 1379
2016-Dec 2359
2017-Apr 1313

References