On September 6, 2019 the IRS announced new procedures (Relief Procedures for Certain Former Citizens) that will enable certain individuals who relinquished their US citizenship to come into compliance with their US tax and filing obligations. The procedures are directed at so-called “accidental Americans” (i.e., citizens of a country other than the United States who could be considered US citizens under relevant provisions of US nationality laws — for example, the individual born in the US to parents temporarily in the US for study or work purposes who returns to his or her country at a young age).

The new procedures are intended to apply only to individuals who

  • have not filed US tax returns as US citizens or residents;
  • owe a limited amount of back taxes to the United States (not in excess of US$25,000); and
  • have net assets of less than US$2MM.

Only individuals whose past non-compliance was non-willful can take advantage of the new procedures.

Benefits to qualifying “accidental Americans” : The new procedures offer relief from taxes, penalties or interest.

The IRS intends to offer an on-line webinar in the near future to provide information in connection with making a submission under the Relief Procedures for Certain Former Citizens.