John Richardson - Counsellor for US persons abroad Profile picture
Expatriation - US Citizenship Renunciation - Green Card Abandonment: US should not impose #FATCA and @citizenshiptax on people with @taxresidency outside US

Jan 18, 2023, 9 tweets

Post from @1040abroad (includes) attempts to define who is an ”Accidental American” (not defined in US law). US Treasury has made consistent attempts to help them without defining them. How should “Accidental American” be defined? taxconnections.com/taxblog/being-… via @TaxConnections

The first recognition of the problem of "Accidental Americans" is found in the 2015 Obama budget proposal discussed here ... See the screen shots for what was proposed. citizenshipsolutions.ca/2015/02/08/the…

The second recognition of the problems of "Accidental Americans" appeared to result in the 2019 "IRS Relief Procedures For Former Citizens" as discussed here ... citizenshipsolutions.ca/2019/12/18/irs…

The third recognition of the problems of "Accidental Americans" comes in the March 2022 Biden Green Book which is designed to allow certain individuals to expatriate easily. citizenshipsolutions.ca/2022/03/29/bid…

The fourth recognition of the problems of (and caused by) "Accidental Americans" came in Dec. 30/22 - Notice 2023 - 11. The effect of the Notice was that FFIs would NOT be required to close the bank accounts of certain Accidentals who do not have SSNs. taxconnections.com/taxblog/the-ca…

The fifth recognition of the problems of (and caused by) Accidental Americans was the Jan. 6/23 announcement by the State Dept that it intended to reduce fee for a CLN from $2350 to the 2012 level of $450. A clear intention to make renunciation easier. citizenshipsolutions.ca/2023/01/10/sta…

It can be inferred that US wishes to remove "Accidental Americans" from US tax base. The preceding five steps are attempts to encourage the easy/painless renunciation of US citizenship in accordance with US law and improve US tax compliance in a @CitizenshipTax and #FATCA world.

The term "Accidental American" is neither a definition nor concept in US tax or nationality law. It will be interesting how US defines the groups of people targeted by various programs/initiatives. For example, the 2019 "Relief Procedures For Former Citizens" is narrowly defined.

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