US Treasury publishes list suggesting record numbers relinquishing US citizenship in 2020 - but what can be inferred from the list?

February 9, 2021 - Participants Include:

Dr. Karen Alpert - @FixTheTaxTreaty

Tim Smyth - @Tpsmyth01

John Richardson - @Expatriationlaw

Internal Revenue Code 6039G requires US Treasury to publish the names of US citizens who relinquish US citizenship. Some refer to the list as the "Name and Shame" list, while others call it the "Liberty List".

6039G in relevant part includes:

"Notwithstanding any other provision of law, not later than 30 days after the close of each calendar quarter, the Secretary shall publish in the Federal Register the name of each individual losing United States citizenship (within the meaning of section 877(a) or 877A) with respect to whom the Secretary receives information under the preceding sentence during such quarter."

Surprisingly there is wide disagreement about:

- exactly which individuals are required to be named on the list (all relinquishers, "covered expatriates" only, Green Card holders?)

- the accuracy of the list (how well does it correlate with the actual numbers of relinquishers)

- the reasons individuals relinquish US citizenship (political or to escape the US tax an/or regulatory net)

In this podcast we discuss: What does the list purport to represent and how accurate is the list?