Tag Archives: S. 877A

Renunciation is one form of relinquishment – It’s not the form of relinquishment, but the time of relinquishment

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Updated August 2020 with this video where this complex issue is discussed

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Tina Turner: What’s FBAR Got To Do With It?

Professor Caron writes:

Washington Post, Tina Turner Formally ‘Relinquishes’ U.S. Citizenship:

This item just in via an “activity” report from the U.S. Embassy in Bern, Switzerland, headlined “Soul Legend Relinquishes U.S. Citizenship.”

“Long-time Swiss resident Tina Turner” was in the embassy Oct. 24 to sign her “Statement of Voluntary Relinquishment of U.S. Citizenship under Section 349 (a)(1) of the INA” — the Immigration and Naturalization Act. …
The key word in the embassy report apparently is the term “relinquishment.” That means, a knowledgeable source told us, that she did not “formally renounce her U.S. citizenship under 349(a)(5) Immigration and Nationality Act, but took Swiss citizenship with the intent to lose her U.S. citizenship.” As opposed to formal renunciation — a much more complex process, we were told — there are no “tax or other penalties for loss of citizenship in this fashion.”
For the difference between relinquishing and renouncing U.S. citizenship, see here. As this detailed post makes clear, the tax consequences are the same whether one relinquishes or renounces U.S. citizenship. Previous press coverage suggested that Ms. Turner’s actions may be motivated in part by a desire to escape the new FATCA regime.

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Tales of renouncing citizenship: U.S. Senator Ted Cruz and London Mayor Boris Johnson

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In September of 2014, I conducted a “Problems of U.S. Citizenship Session” in Montreal, Canada. As usual many of the attendees were in the midst of their OMG (“Oh My God Moment”). The phrase “OMG Moment” is well known. But, what is the “OMG Moment”? I suggest that the “OMG” moment is one of two things. It is either:
1. The moment that those who believe that they are U.S. citizens (or other “U.S. persons”) learn that  they are required (even though they don’t live in the U.S.A.) to obey U.S. tax laws, file U.S. tax and information returns, and are subject to the draconian life altering penalties that are part of membership  in Club U.S.A.; or
2. The moment that they learn for the first time that they may be considered to be a U.S. citizen (or other U.S.person).
This post will focus on those in the second group. That is on:
Those who do NOT believe and have not believed they are U.S. citizens and are learning that they “may be considered to be a U.S. citizen”. 
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