The Internal Revenue Service recently released 2nd quarter data on the number of U.S. Citizens renouncing their citizenship. Thus far in 2016, over 1600 individuals have taken steps to officially expatriate from the U.S. Unsurprisingly, the vast majority of expatriation activity is driven by taxes—U.S. taxes to be precise.
As any U.S. citizen living abroad can tell you, the U.S. taxes its citizens’ income on a worldwide basis. Thus, unlike nearly every industrialized country in the world, U.S. citizens living in Germany, France, Hong Kong or Japan remain subject to U.S. tax—even if their only earned income arises in a foreign country. In addition to the burden of U.S. taxes, U.S. citizens living abroad also face significant filing and reporting requirements—each of which frequently comes with a corresponding bill from the requisite CPA or tax attorney needed to assist in preparation of the necessary forms.
As the IRS numbers indicate, many former U.S. citizens have simply cut ties altogether—eliminating the frustration of trying to calculate U.S. taxes on already taxed overseas income, and remembering to file FBARs reporting foreign accounts held overseas. But as more and more individuals look to escape the U.S. tax albatross, one question people have begun to ask is whether now is the time to go? The immediate answer is not necessarily.
One item worth considering is whether any change is on the horizon to the U.S.’s worldwide taxation system. Some in Congress have realized the problem the current system poses for U.S. citizens and businesses operating overseas and have suggested reverting to the more frequently used “territorial approach”, where U.S. taxation would stop at the water’s edge. Perhaps even a new U.S. Presidential administration would see the light and embrace a territorial tax system to encourage more U.S. expats to maintain their citizenship once they’ve moved overseas. U.S. businesses would certainly benefit from an increased ability to convince their U.S. employees to willingly take overseas assignments.
Given the uncertainty surrounding the upcoming U.S. Presidential election, it may make sense to put any expatriation plans on hold—perhaps at least until November 9th.