Andrew Mitchel LLC

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Update on 1997 Expatriation Data


Today Curtis Poe at kindly notified me of certain comments made in a February 2003 Joint Committee on Taxation report titled “Review of the Present-Law Tax and Immigration Treatment of Relinquishment of Citizenship and Termination of Long-Term Residency” JCS-2-03.

In the GAO response to questions posed by the Joint Committee on Taxation, the number of U.S. citizens expatriating for the years 1991 to 1999 was listed in a table.  However, the years 1995 to 1997 were lumped together with a footnote that stated:

Data for 1995-1997 are not distinguished by year because the IRS published the total number of expatriates for all three years in 1997 (the year after the requirement was enacted.

It is not entirely clear whether even this statement is accurate, because the I.R.S. published expatriate data for the last quarter of 1996.  There were a total of 90 published expatriates for the last quarter of 1996.  I did not include these expatriates in my annual chart, which is why my number for 1997 differs from the GAO number for 1995-1997. 

Further, the number for 1998 in the GAO's table is incorrect.  The original list for the 2nd quarter of 2008 was published on August 11, 1998.  However, this list was an exact duplicate of the 4th quarter 1997 list.  A corrected list was published in the Federal Register on March 20, 2000.  The numbers on my chart reflect the corrected list.

In any case, it appears that my speculation about the 1997 spike in expatriations due to Hong Kong being handed over to China may be incorrect.

Further, the data for 1997 and prior to 1997 only includes U.S. citizens losing their citizenship and does not include long term U.S. permanent residents terminating their U.S. residency status.  Because the 1997 data is not comparable and is not reliable, I will no longer include 1997 in my charts.

Expats 1998-2011

Tags: 877A Individual Expatriation