The explanation is as follows:
SUMMARY: This notice is provided in accordance with IRC section 6039G of the Health Insurance Portability and Accountability Act (HIPPA) of 1996, as amended. This listing contains the name of each individual losing United States citizenship (within the meaning of section 877(a) or 877A) with respect to whom the Secretary received information during the quarter ending September 30, 2012. For purposes of this listing, long-term residents, as defined in section 877(e)(2), are treated as if they were citizens of the United States who lost citizenship.For a chart showing the renouncers over the years 2005 to present, see Andrew Mitchel's International Tax Blog here.
Hat tip to Tax Prof Blog, here.
Jack-
ReplyDeleteI just finished your book on Federal Tax Crimes. Well done,
sir. You articulate many scenarios and aspects of tax "protester"
theories in some enlightening ways that I certainly never thought of.
After dealing wiith a steady stream of meritless legal arguments since
around 2005, when I was first exposed to this "movement," I have
reluctantly come up with my own way of dealing with these individuals
that I have been destined to defend, and your effort and focus on this
topic is greatly appreciated.
I haven't run into anyone involved in renouncing their citizenship, but admittedly now, I remember hearing it referenced once or twice. I always thought that it wasn't possible for a US citizens to renounce or "expatriate" as it were. This is undoubtedly another brilliant attempt for the tax-protester, Sovereign-Freeman kook to try to get away with something that they were probably getting away with anyway. I wonder what the ramifications of this will be, as it certainly won't cause anyone to NOT get arrested or NOT have to pay their taxes...
-Matthew Whitten
Just to give a name of someone who is cited here a lot I know that Ellen Wallace of Geneva Lunch(a prominent English language website in Switzerland that is often referred to due to its coverage of the whole UBS affair and other Swiss shenanigans) is a renounced US citizen. In the past up to the late 1980s generally people lost their US citizenship through relinquishment if they become a citizen of another country. Up to even a few years ago a US citizen had to give up their citizenship for example if they wanted to become and Australian Citizen.
ReplyDeleteOne of the issues is as US Nationality law has changed and that those who lost US citizenship in the past can get their citizenship back the IRS General Counsel's office has been taking the view in different revenue rulings since the 1970's when the first of these changes started to come through the system that these individuals are US citizens for tax law purposes even if they don't exercise any benefits of US citizenship such as voting or applying for a passport(Many lawyers have questions with this interpretation of the law and its not exactly clear whether the IRS GC's truely stands by it to the end).
Mr Whitten, Please note that I am on the list. I relinquished (not renounced) my citizenship: here is how much I owed US taxes that I owed for each of the last five years (respectively) and what I reported on my Form 8854: $0.00,$0.00,$0.00;$0.00;$0.00.
ReplyDeleteSo you see that I have not deprived the poor depraved United States treasury of any income. But now I am free. I don't have to worry about my bank telling the IRS about my bank accounts; I don't have to file US income taxes; I don't have to file FBARs. But today, an article at iexpats.com has appeared that features my fear of returning to the United States because, while I relinquished my citizenship, I did not relinquish my human rights and accept handing over information to the IRS that under the constitution requires reasonable cause and warrant with my name on it. I refuse. But since the United States government no longer respects the constitutional rights of Americans, many find it necessary to relinquish my US citizenship. Few of the people I know who renounce their citizenship are actually "tax-protester, Sovereign-Freeman kooks".
You should learn more about the US Federal government's mistreatment of those who renounce their US citizenship and not resort to knee-jerk reaction. It is unbecoming.
Peter W. Dunn, Isaac Brock Society
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ReplyDeleteThe practice of random selection has been a source of controversy for many years, and was even suspended for a short time in the early 2000s amid criticism that the audits were too burdensome and intrusive. The IRS revived the practice in the fall of 2006.
Remember, in addition to any ‘findings’ by the auditor of unpaid taxes, you will also be assessed interest and penalties.
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