The single biggest mistake that most* people can make in renouncing U.S. citizenship is:

To renounce without a clear and accurate understanding of their net worth**.

*Some with @dualcitizenship from birth "may" avoid the consequences of a net worth > 2 mill USD.

(**Incredibly…

— John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) April 7, 2025

In the last week I have had discussions with two people who reached out to me AFTER renouncing U.S. citizenship. In both cases they went to their renunciation appointment and renounced U.S. WITHOUT understanding their net worth. Specifically, they never considered whether their net worth was above or below 2 million USD. Unless they were able to avail themselves of the “dual citizenship from birth” exemption from “covered expatriate status”, knowing their net worth on the date of renunciation was critical. In fact, this is the single biggest mistake one can make.

In both cases their net worth was well above two million USD making them:

1. Subject to the 877A Exit Tax; and

2. Subject to the Internal Revenue Code 2801 “Covered Gift” rules

In both cases they claim that they were advised that they should first renounce U.S. citizenship and then deal with the tax situation (the worst possible advice imaginable)!

In both cases the consequences were “life altering” (sorry no exagerration).

As Benjamin Franklin is reported to have said:

“Those who fail to plan, plan to fail.”

John Richardson – Follow me on X.com @ExpatriationLaw