409:) directing DHS to report, within 90 days of the act's passage, on the steps it was undertaking to enforce the Reed Amendment, including a schedule for issuing guidance or regulations, if necessary. DHS' report, submitted to Congress in November 2015, stated that "there currently are no advisable options for altering enforcement of the inadmissibility ground against persons who do not affirmatively admit to renouncing their U.S. citizenship for the purpose of avoiding U.S. taxation". DHS considered implementing the Reed Amendment by presuming that a former citizen seeking entry had renounced U.S. citizenship for the purpose of avoiding taxation if he or she failed to pay the expatriation tax, obtained a windfall shortly after renunciation, or established residence in a
472:
overcome; in FY 2017, there was one ineligibility finding and one overcome. Charles M. Bruce of Moore & Bruce LLP states that some U.S. consular officers may have "unofficially and improperly" applied the Reed
Amendment to refuse issuance of visas to former U.S. citizens. Mark Nestmann similarly states that he knows of occasional cases in which former citizens have been denied U.S. visas, with consuls citing the Reed Amendment as their authority. Nevertheless, Eugene Chow of Chow & King Associates states that in spite of the Reed Amendment, consular officers "routinely issue visas" to ex-U.S. citizens, and the State Department's
394:
the required determination of tax motivation, as no IRS staff might be available to respond to the request for information on a weekend. Additionally, the IRS already had a large workload drafting other guidance for former citizens and green card holders under newly passed tax laws. Furthermore, DHS later indicated that even if the department were able to obtain tax information on former citizens, their agents "lack the expertise and resources to review tax filings meaningfully or engage in complicated tax liability analysis, involving both domestic and foreign tax law". In the end, the proposed regulations were never issued.
678:
319:, including (1) obtaining nationality in a foreign country, (2) swearing allegiance to a foreign government, (3) serving in a foreign military under certain conditions, or (4) working for a foreign government), or only those who specifically "renounced" by making a formal renunciation of nationality under § 1481(a)(5) or (6). Mark Nestmann of The Nestmann Group states that despite non-enforcement of the Reed Amendment, he advises his clients to avoid making a formal renunciation of nationality, and instead to naturalize as a citizen of a foreign country and then obtain a U.S.
20:
332:
783:, adding provisions to account for the possibility that a former citizen who met the asset or tax liability thresholds to trigger the tax might subsequently spend significant amounts of time in the United States. Kirsch describes this as "implicit recognition" of the "substantive and technical problems" of the Reed Amendment. Kirsch outlined an alternative proposal to more narrowly tailor the Reed Amendment in a way he suggested would make it enforceable.
430:
413:, and placing the burden of proof on the individual to rebut this presumption; however, the department concluded that this procedure would have both many false negatives (failing to identify people who renounced for tax avoidance reasons) as well as many false positives (incorrectly denying entry to people who had other reasons for renouncing U.S. citizenship).
255:
unenforceable ... This is the way we legislate at 5 o'clock in the morning 4 days before adjournment." Moynihan went on to state that it was inappropriate to use visa restrictions to enforce the tax law, called it a provision "which does not reflect well on a free society", and advocated for the alternative plan of modifying the
455:
has no procedures in effect to implement the Reed
Amendment. The FAM instructs consular officers that "he role of the Department and the consular officer is very limited in implementing this ground of inadmissibility. Unless the applicant appears as a hit in the lookout system revealing a finding of
393:
However, there were various practical difficulties with these proposed regulations. Most notably, only one IRS agent would have been assigned to handling such requests; if a former U.S. citizen arrived on a weekend, he or she might have to be detained until Monday in order for border agents to make
262:
Among various academics' and practitioners' criticisms of the law, Renee S. Liu describes it as "an inappropriate response" to the problem it sought to address, while
Michelle Leigh Carter argues that it may "unconstitutionally infringe on the fundamental right to expatriate". Temple University law
254:
made a speech on the Senate floor denouncing the Reed
Amendment in harsh terms, saying: "The wording of the statute is embarrassing. How can an alien renounce U.S. citizenship? In what capacity would said alien do so officially? One assumes that a court of law would find the language incoherent and
198:
both wrote to the State
Department to protest, and by October 1995, the government of Belize had withdrawn its nomination of Dart as consul. Wealthy people who renounced U.S. citizenship for tax reasons were estimated to comprise about a dozen of the roughly one thousand people per year who became
80:
has stated that they cannot obtain the information required to enforce the amendment unless the former U.S. citizen "affirmatively admit" his or her reasons for renouncing citizenship, and so from 2002 to 2015, only two people were denied entry to the United States on the grounds of the amendment.
471:
included the relevant statistics, and 2015, no consular officer found any visa applicant ineligible for entry into the United States on the grounds of the Reed
Amendment. However in the Department of State Fiscal Year 2016 report, there were two INA 212(a)(10(E) findings and one ineligibility
535:
Any alien who is a former citizen of the United States who relinquishes United States citizenship (within the meaning of section 877A(e)(3) of the
Internal Revenue Code of 1986) and who is determined by the Attorney General, after consultation with the Secretary of the Treasury, not to be in
807:
308:
Michael G. Pfeifer of Caplin & Drysdale states that it is unclear whether the Reed
Amendment is intended to apply to all persons "relinquishing" U.S. citizenship by committing an "expatriating act" with the intention of losing U.S. citizenship (all the acts listed in
335:
Passport control at John F. Kennedy
International Airport. U.S. Customs and Border Patrol officers decide whether former U.S. citizens arriving in the U.S. are inadmissible based on the Reed Amendment. They have only found two people inadmissible in the past 15
119:
Any alien who is a former citizen of the United States who officially renounces United States citizenship and who is determined by the
Attorney General to have renounced United States citizenship for the purpose of avoiding taxation by the United States is
940:
416:
According to the DHS report, two individuals were denied admission to the United States on the grounds of the Reed Amendment between 2002 and 2015, while another five individuals "were identified as possibly inadmissible" on that basis but were not
764:
96:, and others have made many unsuccessful efforts to enact clearer definitions of the classes of former citizens to be banned from re-entry, and to enable executive agencies to share information with each other in order to enforce the ban.
75:
later criticised it as inappropriate, embarrassing, and badly-drafted. Efforts at establishing procedures to enforce the amendment ran into early difficulties, and the executive branch never promulgated the implementing regulations. The
816:
149:
should "not be able to return to the United States". At the time, the issue of giving up U.S. citizenship for tax purposes was receiving a large amount of media attention, which also resulted in Congress adding provisions to the
170:. Reed's amendment ostensibly intended to address the issue of wealthy individuals who had renounced U.S. citizenship but then later attempted to obtain residency visas to return to the United States. One example discussed was
421:. Joel Paget of Ryan, Swanson & Cleveland states that one such denial (against a person who renounced before the enactment of the Reed Amendment) was reversed after the renunciant's lawyer submitted a legal brief to CBP.
292:
The U.S. government has never issued regulations to implement the Reed Amendment. One issue with the enforcement of the law was that the Attorney General was never authorized to obtain the required information from the
1969:
231:
65:
365:
167:
1237:
441:'s application for a U.S. visa, but he states that he was later able to obtain a visa from the U.S. Embassy in Tokyo. Sources disagree whether the Reed Amendment had anything to do with this visa rejection.
637:), while the Senate Finance Committee or its members inserted these provisions into various House-originated bills as well. One of the attempts which saw the most support was in a Senate version of the
767:, but their amendment did not appear in the final version of the bill which passed the Senate in June that year, nor in the version of the bill which was introduced in the House in October that year.
1863:
456:
inadmissibility under INA 212(a)(10)(E), you must assume the applicant is eligible." Finally, the FAM states that a person who is found inadmissible due to the Reed Amendment could request a
402:
376:
the waiver to the IRS so that the IRS could provide Customs with tax information relating to the former citizen, in particular whether the former citizen met the asset thresholds of
1805:
1637:
53:. The United States is one of two countries in the world that taxes its citizens' income earned abroad for citizens whose primary residence is abroad. The other country to do so is
206:
approved Reed's amendment by a vote of 25 to 5, over objections from opponents of the law arguing that it was punitive, difficult to enforce, and gave too much discretion to the
1900:
276:
1304:
740:
had renounced his U.S. citizenship, there was speculation that the Reed Amendment might be invoked against him, and Reed himself (by then senior RI senator) sent a letter to
369:
151:
897:
1959:
398:
681:
Representative Lamar S. Smith (R-TX), who originally opposed the Reed Amendment, later attempted to broaden it to cover all people who had renounced U.S. citizenship.
763:
on their U.S. investments, but it died in committee. The following year, Reed himself, along with Schumer and Casey, moved the Ex-PATRIOT Act as an amendment to the
447:
859:
Kirsch, Michael S. (2004). "Alternative Sanctions and the Federal Tax Law: Symbols, Shaming, and Social Norm Management as a Substitute for Effective Tax Policy".
203:
77:
494:
and clarify its scope. Academics have also written papers in legal journals suggesting changes to the Reed Amendment. None of these proposals have become law.
1524:
741:
578:
to allow the Internal Revenue Service to share ex-citizens' tax information with the Attorney-General in order to enforce the entry ban. In September 2002,
145:). He stated that "there's no attempt by this legislation to prevent someone from renouncing their citizenship", but that people who did so for purposes of
1505:. U.S. Department of State. Retrieved 2014-06-05. The statistics on legal grounds which resulted in zero findings of ineligibility are not included in the
963:
1041:
1867:
1482:
923:
297:
in order to be able to make the determination whether a former American's loss of citizenship was motivated by tax reasons. This restriction arises from
1964:
1510:
1498:
1494:
1490:
1486:
990:
Immigration in the National Interest Act of 1995: Report of the Committee on the Judiciary on H.R. 2202, together with dissenting and additional views
46:
457:
105:
665:), but not its inadmissibility or tax information privacy waiver provisions, passed into law as part of a veteran's assistance bill sponsored by
1441:"Table XX: Immigrant and Nonimmigrant Visa Ineligibilities (by Grounds for Refusal Under the Immigration and Nationality Act) for Fiscal Years
760:
372:
of 1996. Those who were identified as former U.S. citizens would be required to sign a waiver of their rights under § 6103; Customs would then
341:
243:
905:
272:
207:
641:, which passed the Senate 94-3 but was never brought up for consideration in the House. The last attempt to introduce this provision was by
1755:
649:
bill in February 2008. In June 2008, the expatriation tax and gift tax provisions of the original Baucus-Bingaman-Burns amendment (i.e.
135:
61:
1513:
report only includes information on immigrant visa ineligibilities and not non-immigrant visa ineligibilities under the Reed Amendment.
1920:
776:
357:
320:
1780:
1042:"Giving Taxpatriates the Boot — Permanently: The Reed Amendment Unconstitutionally Infringes on the Fundamental Right to Expatriate"
695:
619:
516:
486:
452:
344:
and the IRS' Office of Associate Chief Counsel (International) worked together in an effort to create procedures to work around the
311:
126:
37:
1407:
1261:
210:. All 12 Democratic members of the committee, as well as 13 of the 18 Republican members, voted in support; the five opposers were
601:
Congresses), many veterans' benefits and tax bills introduced in the Senate contained the above provisions (i.e. the enactment of
685:
The Securing America's Freedom Through Enforcement Reform Act, an immigration reform bill introduced by Reed Amendment opponent
677:
893:
Review of the Present-Law Tax and Immigration Treatment of Relinquishment of Citizenship and Termination of Long-Term Residency
461:
195:
50:
484:
Since 2002, both Democratic and Republican legislators have introduced bills or amendments aiming to change the language of
714:
Any alien who is a former citizen of the United States who officially renounced United States citizenship is inadmissible.
638:
353:
141:
Reed first introduced his eponymous amendment during the debate on the Immigration in the National Interest Act of 1995 (
1011:
598:
594:
590:
71:
Though the Reed Amendment received strong bipartisan support during the committee stage, Democratic lawmakers including
987:"33. Amendment offered by Mr. Reed excluding from entry persons who renounce U.S. citizenship to avoid paying taxes".
583:
473:
234:, contained the Reed Amendment in its originally-introduced version, and went on to be enacted on September 30, 1996.
1478:
1474:
1943:
1466:
1462:
1282:
941:"The Expatriate Exclusion Clause: An Inappropriate Response to Relinquishing Citizenship for Tax Avoidance Purposes"
19:
1685:
1596:
1525:"Acquisition of Chinese nationality in the Hong Kong Special Administrative Region and Expatriation under U.S. law"
1329:
1506:
1450:
1446:
1442:
1113:
294:
268:
108:'s list of "Classes of aliens ineligible for visas or admissions", under the "Miscellaneous grounds" category:
1571:
988:
919:
751:(D-NY) stated that the Reed Amendment "was written in a manner that inhibits its enforcement", and so he and
1470:
1458:
251:
72:
1088:
1851:
1832:"Schumer, Casey announce plan to stop Facebook Co-Founder from dodging taxes by dropping U.S. citizenship"
1697:
1633:
1551:
1305:"Senator Reed Again Proposes Special 'Tax Expatriation' Legislation Adverse to Former Citizens (not LPRs)"
1238:"Past And Proposed Anti-Expat Legislation: Interview With Bill Yates, Former IRS Attorney (International)"
1652:
1617:
1454:
718:
The same provision was also included in bills introduced in 2003 and 2005; it did not pass either time.
658:
650:
629:
610:
602:
570:
561:
553:
387:
378:
345:
298:
246:
Senator Daniel Moynihan (D-NY) stated that the Reed Amendment "does not reflect well on a free society".
159:
1144:
1114:"The U.S. Tax Consequences of Expatriation: Is It a Tax Planning Opportunity or a Trap for the Unwary?"
689:(R-PA) in July 2002, and co-sponsored by 44 other Republicans including fellow Reed Amendment opponent
331:
815:. Fiscal Year 2015 Report to Congress. Washington, DC: Department of Homeland Security. Archived from
759:, which would make certain former U.S. citizens inadmissible to the United States and charge them 30%
1178:"United States: The Final State of Expatriation? Omissions and Technical Issues Under the HEART Act"
418:
1694:
1383:"9 FAM 302.10-6: Former Citizens Who Renounced Citizenship to Avoid Taxation - INA 212(a)(10)(E)"
1177:
1071:
219:
1669:
1629:
406:
390:
regarding whether or not the former citizen had tax motivations for giving up U.S. citizenship.
1734:
1722:
1710:
1681:
1641:
1625:
1621:
1613:
1592:
1555:
514:(R-MT) sponsored an amendment to an appropriations bill to add a provision which would rewrite
142:
49:. Notably, entry can be denied to persons who renounced their U.S. citizenship to avoid paying
45:) attempting to impose an entry ban on certain former U.S. citizens based on their reasons for
1912:
1831:
1738:
1726:
1609:
1582:
901:
868:
666:
187:
1916:
1887:
1382:
891:
872:
464:
to obtain a non-immigrant visa, but that no waiver is available to obtain an immigrant visa.
1810:
1656:
1205:
780:
744:
646:
545:
256:
155:
1806:"Billionaire Facebook Cofounder Could Be Barred From America After Renouncing Citizenship"
1283:"Department of Homeland Security Appropriations Bill, 2015: Report (To accompany S. 2534)"
1210:
737:
703:
to cover all renunciants regardless of whether or not they had tax avoidance motivations:
1418:
1330:"Income and Estate Tax Planning on a Linear Basis for the Inbound and Outbound Resident"
833:
699:
623:
520:
490:
130:
41:
756:
752:
727:
690:
582:(D-IA) added the same language to the Armed Forces Tax Fairness Act of 2002 during the
227:
175:
93:
89:
429:
242:
1953:
748:
642:
507:
382:
361:
279:
that all people have the right to leave any country and to change their nationality.
223:
146:
85:
633:
574:
686:
511:
315:
215:
211:
171:
1864:"Reed Offers Amendment to Prevent Ex-Citizen Tax Dodgers from Reentering the U.S."
1608:
A partial list includes the Veterans and Military Personnel Fairness Act of 2003,
662:
654:
614:
606:
565:
557:
349:
302:
1357:
476:
has reversed denials based on the Reed Amendment after being made aware of them.
163:
1285:. S. Rept. 113-198. United States Senate Committee on Appropriations. 2014-06-26
765:
Border Security, Economic Opportunity, and Immigration Modernization Act of 2013
264:
191:
183:
1143:
Bruce, Charles M.; Saret, Lewis; Lagonico, Stéphane; Trow, Steve (2006-03-13).
536:
compliance with sections 877A and 2801 of such Code (relating to expatriation).
579:
503:
360:) would have been required to check the names of all aliens appearing at U.S.
1586:
340:
According to retired IRS international tax counsel Willard Yates, the former
1730:
530:(E) Former citizens not in compliance with expatriation revenue provisions.—
438:
410:
323:
on the basis of having committed an "expatriating act" under § 1481(a)(1).
733:
549:
54:
84:
Various Democratic and Republican politicians including Reed himself,
1725:; Securing America's Freedom Through Enforcement Reform Act of 2005,
540:
The Baucus-Bingaman-Burns amendment also included a variety of other
179:
1779:
Prasso, Sheridan; Vallikappen, Sanat; Drucker, Jesse (2012-05-18).
1721:
Securing America's Freedom Through Enforcement Reform Act of 2003,
232:
Illegal Immigration Reform and Immigrant Responsibility Act of 1996
66:
Illegal Immigration Reform and Immigrant Responsibility Act of 1996
676:
541:
428:
330:
241:
18:
1781:"Facebook's Saverin Says Tax Bill Will Be 'Hundreds of Millions'"
1946:
urging enforcement of the Reed Amendment against Eduardo Saverin
401:
to insert language into the Senate report on one version of the
114:(E) Former citizens who renounced citizenship to avoid taxation
467:
Between 2000, the first year for which the State Department's
373:
1970:
United States federal immigration and nationality legislation
1572:"Uncle Sam Wants You (To Pay Tax): Breaking Up Is Hard To Do"
1554:
to the Supplemental Appropriations Act for Fiscal Year 2002,
250:
In the aftermath of IIRIRA's passage, Reed's fellow Democrat
836:. Legal Information Institute, Cornell University Law School
1709:
Securing America's Freedom Through Enforcement Reform Act,
544:
related to former citizens, among them new versions of the
1262:"Reed Helps Advance Homeland Security Appropriations Bill"
747:
urging her to bar Saverin from re-entry. However, Senator
366:
list of former United States citizens published by the IRS
168:
make public the names of people giving up U.S. citizenship
1112:
Buss, David; Hryck, David; Granwell, Alan (August 2007).
1756:"Schumer Proposes Tax On People Like Facebook's Saverin"
403:
Department of Homeland Security Appropriations Act, 2015
1640:; the Small Business and Work Opportunity Act of 2007,
1638:
Tax Increase Prevention and Reconciliation Act of 2005
1534:. 57th Congress of the Union International des Avocats
1417:. U.S. Department of State. 2011-10-06. Archived from
1358:"7 FAM 1200: Loss and Restoration of U.S. Citizenship"
1612:; the Armed Forces Tax Fairness Act of 2003 (AFTFA),
1565:
1563:
964:"Exile's Effort to Return Puts Focus on Tax Loophole"
568:
mentioned in the above quote), as well as changes to
1749:
1747:
1231:
1229:
1227:
809:
Inadmissibility of Tax-Based Citizenship Renunciants
277:
International Covenant on Civil and Political Rights
35:, created a provision of United States federal law (
1680:Heroes Earnings Assistance Relief Tax Act of 2008,
370:
Health Insurance Portability and Accountability Act
152:
Health Insurance Portability and Accountability Act
104:The Reed Amendment added the following text to the
1686:
898:United States Congress Joint Committee on Taxation
1591:Q.v. the Armed Forces Tax Fairness Act of 2002,
1570:McLemore, Chris; Fraser, Erin (September 2015).
1012:"Expatriation provision of the immigration bill"
124:This provision is located at INA 212(a)(10)(E) (
709:(E) Former citizens who renounced citizenship.—
693:(R-TX), would have broadened the entry ban in
801:
799:
797:
795:
8:
854:
852:
850:
397:In June 2014, Reed used his position on the
134:). It was introduced by then-Representative
1866:reed.senate.gov. 2013-06-12. Archived from
1595:, and the Senate Finance Committee report,
1337:Immigration Law for Non-Immigration Lawyers
1199:
1197:
451:(FAM), due to the lack of regulations, the
1089:"Will Congress Move to Tax 'Ex-Patriots'?"
993:. House Report 104-469, Part 1. 1995-03-04
779:, Congress amended the law concerning the
267:also suggested that it conflicts with the
934:
932:
886:
884:
882:
433:The U.S. Embassy in Bridgetown, Barbados
1960:Acts of the 104th United States Congress
1138:
1136:
1668:American Renewable Energy Act of 2008,
791:
755:(D-PA) introduced new legislation, the
480:Further unenacted legislative proposals
106:Immigration and Nationality Act of 1952
60:The Amendment was named for its author
1532:Nationality and Immigration Commission
1389:. U.S. Department of State. 2016-03-07
1364:. U.S. Department of State. 2008-08-06
1236:Virginia La Torre Jeker (2013-12-30).
352:limitation. Under their proposal, the
342:Immigration and Naturalization Service
259:to tax accrued capital gains instead.
1145:"The Exit Tax — A Perfectly Bad Idea"
437:rejected ex-U.S. citizen businessman
273:Universal Declaration of Human Rights
64:, and passed into law as part of the
7:
834:"8 USC § 1182: Inadmissible Aliens"
283:Official and unofficial enforcement
271:, as well as the guarantees in the
186:to serve as Belize's new consul in
1691:Tooltip Public Law (United States)
1176:Pfeifer, Michael G. (2009-09-28).
945:Georgetown Immigration Law Journal
777:American Jobs Creation Act of 2004
399:Senate Committee on Appropriations
321:Certificate of Loss of Nationality
230:(R-TX). Another similar bill, the
14:
1901:"The Tax Code as Nationality Law"
1620:to another version of the AFTFA,
1579:Tax Planning International Review
1072:"U.S. erects a Berlin (Tax) Wall"
900:. February 2003. pp. 71–72.
732:In May 2012, following news that
1965:Visa policy of the United States
1944:Reed's 2012 letter to Napolitano
1834:. schumer.senate.gov. 2012-05-17
1804:Carlson, Nicholas (2012-05-16).
1624:; another version of the AFTFA,
204:House Committee on the Judiciary
100:Overview and legislative history
1754:Hunter, Kathleen (2012-05-18).
1040:Carter, Michelle Leigh (2002).
589:From then until 2008 (i.e. the
498:Baucus–Bingaman–Burns amendment
425:In the visa application process
182:and then attempted to obtain a
78:Department of Homeland Security
23:Reed Amendment author Jack Reed
1905:Harvard Journal on Legislation
1628:; the Tax Relief Act of 2005,
1303:Martin, Patrick (2014-06-29).
806:Johnson, Jeb C. (2015-11-30).
742:Secretary of Homeland Security
178:, who had become a citizen of
1:
1737:; nor the SAFER Act of 2013,
1328:Paget, Joel H. (2012-09-12).
1264:. reed.senate.gov. 2014-06-26
1204:Nestmann, Mark (2011-06-28).
962:De Witt, Karen (1995-10-01).
639:Fair Minimum Wage Act of 2007
358:Customs and Border Protection
1339:. Washington Bar Association
1121:International Tax Strategies
920:in PDF form from the website
1899:Kirsch, Michael S. (2006).
1729:. It is not related to the
1523:Chow, Eugene (2013-11-02).
1087:Spiro, Peter (2012-05-17).
1070:Spiro, Peter (2008-07-18).
584:Joint Committee on Taxation
474:Office of the Legal Adviser
47:renouncing U.S. citizenship
33:Expatriate Exclusion Clause
1986:
1659:, sponsored by Max Baucus.
924:Government Printing Office
725:
1636:by Chuck Grassley to the
1503:Report of the Visa Office
1206:"Relinquish or Renounce?"
1022:(141): S12297. 1996-10-03
469:Report of the Visa Office
458:Waiver of Inadmissibility
617:, and the amendments to
295:Internal Revenue Service
269:Expatriation Act of 1868
1152:Tax Notes International
252:Daniel Patrick Moynihan
73:Daniel Patrick Moynihan
1415:Foreign Affairs Manual
1387:Foreign Affairs Manual
1362:Foreign Affairs Manual
939:Liu, Renee S. (1998).
682:
448:Foreign Affairs Manual
442:
337:
247:
190:. Florida Congressmen
24:
1408:"9 FAM 40.105: Notes"
700:§ 1182(a)(10)(E)
680:
624:§ 1182(a)(10)(E)
521:§ 1182(a)(10)(E)
491:§ 1182(a)(10)(E)
432:
388:private letter ruling
334:
245:
131:§ 1182(a)(10)(E)
42:§ 1182(a)(10)(E)
22:
1016:Congressional Record
586:markup of the bill.
31:, also known as the
453:Department of State
16:US legal instrument
1509:report, while the
1046:Georgia Law Review
968:The New York Times
683:
443:
338:
248:
220:Carlos J. Moorhead
25:
1852:S.Amdt. 1252
1634:S.Amdt. 2707
1552:S.Amdt. 3628
918:; also available
907:978-0-16-054212-1
761:capital gains tax
667:Charles B. Rangel
552:for ex-citizens (
445:According to the
327:At ports of entry
188:Sarasota, Florida
1977:
1932:
1931:
1929:
1928:
1919:. Archived from
1896:
1890:
1885:
1879:
1878:
1876:
1875:
1860:
1854:
1849:
1843:
1842:
1840:
1839:
1828:
1822:
1821:
1819:
1818:
1811:Business Insider
1801:
1795:
1794:
1792:
1791:
1776:
1770:
1769:
1767:
1766:
1751:
1742:
1719:
1713:
1707:
1701:
1692:
1688:
1678:
1672:
1666:
1660:
1653:S.Amdt. 100
1650:
1644:
1618:S.Amdt. 433
1606:
1600:
1590:
1576:
1567:
1558:
1549:
1543:
1542:
1540:
1539:
1529:
1520:
1514:
1439:
1433:
1432:
1430:
1429:
1423:
1412:
1404:
1398:
1397:
1395:
1394:
1379:
1373:
1372:
1370:
1369:
1354:
1348:
1347:
1345:
1344:
1334:
1325:
1319:
1318:
1316:
1315:
1309:Tax Expatriation
1300:
1294:
1293:
1291:
1290:
1279:
1273:
1272:
1270:
1269:
1258:
1252:
1251:
1249:
1248:
1233:
1222:
1221:
1219:
1218:
1201:
1192:
1191:
1189:
1188:
1173:
1167:
1166:
1164:
1163:
1149:
1140:
1131:
1130:
1128:
1127:
1118:
1109:
1103:
1102:
1100:
1099:
1085:
1083:
1082:
1067:
1061:
1060:
1058:
1057:
1037:
1031:
1030:
1028:
1027:
1008:
1002:
1001:
999:
998:
984:
978:
977:
975:
974:
959:
953:
952:
936:
927:
917:
915:
914:
888:
877:
876:
856:
845:
844:
842:
841:
830:
824:
823:
821:
814:
803:
781:expatriation tax
745:Janet Napolitano
702:
647:renewable energy
636:
626:
577:
546:expatriation tax
542:spending offsets
523:
493:
462:INA 212(d)(3)(A)
385:
383:§ 877(a)(2)
318:
257:expatriation tax
208:Attorney General
156:expatriation tax
154:to broaden the "
133:
44:
1985:
1984:
1980:
1979:
1978:
1976:
1975:
1974:
1950:
1949:
1940:
1935:
1926:
1924:
1898:
1897:
1893:
1886:
1882:
1873:
1871:
1862:
1861:
1857:
1850:
1846:
1837:
1835:
1830:
1829:
1825:
1816:
1814:
1803:
1802:
1798:
1789:
1787:
1778:
1777:
1773:
1764:
1762:
1753:
1752:
1745:
1720:
1716:
1708:
1704:
1690:
1679:
1675:
1667:
1663:
1651:
1647:
1607:
1603:
1597:S.Rept. 107-283
1574:
1569:
1568:
1561:
1550:
1546:
1537:
1535:
1527:
1522:
1521:
1517:
1440:
1436:
1427:
1425:
1421:
1410:
1406:
1405:
1401:
1392:
1390:
1381:
1380:
1376:
1367:
1365:
1356:
1355:
1351:
1342:
1340:
1332:
1327:
1326:
1322:
1313:
1311:
1302:
1301:
1297:
1288:
1286:
1281:
1280:
1276:
1267:
1265:
1260:
1259:
1255:
1246:
1244:
1235:
1234:
1225:
1216:
1214:
1211:LewRockwell.com
1203:
1202:
1195:
1186:
1184:
1175:
1174:
1170:
1161:
1159:
1147:
1142:
1141:
1134:
1125:
1123:
1116:
1111:
1110:
1106:
1097:
1095:
1086:
1080:
1078:
1069:
1068:
1064:
1055:
1053:
1039:
1038:
1034:
1025:
1023:
1010:
1009:
1005:
996:
994:
986:
985:
981:
972:
970:
961:
960:
956:
938:
937:
930:
912:
910:
908:
890:
889:
880:
861:Iowa Law Review
858:
857:
848:
839:
837:
832:
831:
827:
819:
812:
805:
804:
793:
789:
773:
738:Eduardo Saverin
730:
724:
694:
675:
628:
618:
569:
515:
500:
485:
482:
427:
377:
354:Customs Service
329:
310:
290:
285:
240:
184:diplomatic visa
125:
102:
36:
17:
12:
11:
5:
1983:
1981:
1973:
1972:
1967:
1962:
1952:
1951:
1948:
1947:
1939:
1938:External links
1936:
1934:
1933:
1911:(2): 375–436.
1891:
1880:
1855:
1844:
1823:
1796:
1785:Bloomberg News
1771:
1760:Bloomberg News
1743:
1735:H.R. 3663
1723:H.R. 3522
1714:
1711:H.R. 5013
1702:
1695:110–245 (text)
1682:H.R. 6081
1673:
1661:
1645:
1622:H.R. 1307
1601:
1593:H.R. 5063
1559:
1556:H.R. 4775
1544:
1515:
1434:
1399:
1374:
1349:
1320:
1295:
1274:
1253:
1223:
1193:
1168:
1132:
1104:
1062:
1032:
1003:
979:
954:
928:
906:
878:
846:
825:
822:on 2016-03-22.
790:
788:
785:
772:
769:
757:Ex-PATRIOT Act
728:Ex-PATRIOT Act
726:Main article:
723:
722:Ex-PATRIOT Act
720:
716:
715:
712:
711:
710:
691:Lamar S. Smith
674:
671:
659:26 U.S.C.
651:26 U.S.C.
634:§ 6103(i)
611:26 U.S.C.
603:26 U.S.C.
575:§ 6103(i)
562:26 U.S.C.
554:26 U.S.C.
538:
537:
533:
532:
531:
502:In June 2002,
499:
496:
481:
478:
426:
423:
362:ports of entry
346:26 U.S.C.
328:
325:
316:§ 1481(a)
299:26 U.S.C.
289:
288:General issues
286:
284:
281:
239:
236:
228:Lamar S. Smith
199:ex-Americans.
176:Dart Container
160:26 U.S.C.
143:H.R. 2202
122:
121:
117:
116:
115:
101:
98:
94:Lamar S. Smith
90:Chuck Grassley
29:Reed Amendment
15:
13:
10:
9:
6:
4:
3:
2:
1982:
1971:
1968:
1966:
1963:
1961:
1958:
1957:
1955:
1945:
1942:
1941:
1937:
1923:on 2015-09-18
1922:
1918:
1914:
1910:
1906:
1902:
1895:
1892:
1889:
1884:
1881:
1870:on 2013-06-17
1869:
1865:
1859:
1856:
1853:
1848:
1845:
1833:
1827:
1824:
1813:
1812:
1807:
1800:
1797:
1786:
1782:
1775:
1772:
1761:
1757:
1750:
1748:
1744:
1740:
1736:
1732:
1728:
1727:H.R. 688
1724:
1718:
1715:
1712:
1706:
1703:
1699:
1696:
1689:
1683:
1677:
1674:
1671:
1665:
1662:
1658:
1654:
1649:
1646:
1643:
1639:
1635:
1631:
1627:
1623:
1619:
1615:
1611:
1605:
1602:
1598:
1594:
1588:
1584:
1580:
1573:
1566:
1564:
1560:
1557:
1553:
1548:
1545:
1533:
1526:
1519:
1516:
1512:
1508:
1504:
1500:
1496:
1492:
1488:
1484:
1480:
1476:
1472:
1468:
1464:
1460:
1456:
1452:
1448:
1444:
1438:
1435:
1424:on 2015-10-14
1420:
1416:
1409:
1403:
1400:
1388:
1384:
1378:
1375:
1363:
1359:
1353:
1350:
1338:
1331:
1324:
1321:
1310:
1306:
1299:
1296:
1284:
1278:
1275:
1263:
1257:
1254:
1243:
1239:
1232:
1230:
1228:
1224:
1213:
1212:
1207:
1200:
1198:
1194:
1183:
1179:
1172:
1169:
1157:
1153:
1146:
1139:
1137:
1133:
1122:
1115:
1108:
1105:
1094:
1090:
1077:
1073:
1066:
1063:
1051:
1047:
1043:
1036:
1033:
1021:
1017:
1013:
1007:
1004:
992:
991:
983:
980:
969:
965:
958:
955:
950:
946:
942:
935:
933:
929:
925:
921:
909:
903:
899:
895:
894:
887:
885:
883:
879:
874:
870:
866:
862:
855:
853:
851:
847:
835:
829:
826:
818:
811:
810:
802:
800:
798:
796:
792:
786:
784:
782:
778:
770:
768:
766:
762:
758:
754:
750:
749:Chuck Schumer
746:
743:
739:
735:
729:
721:
719:
713:
708:
707:
706:
705:
704:
701:
697:
692:
688:
679:
672:
670:
668:
664:
660:
656:
652:
648:
644:
643:Amy Klobuchar
640:
635:
631:
625:
621:
616:
612:
608:
604:
600:
596:
592:
587:
585:
581:
576:
572:
567:
563:
559:
555:
551:
547:
543:
534:
529:
528:
527:
526:
525:
522:
518:
513:
509:
508:Jeff Bingaman
505:
497:
495:
492:
488:
479:
477:
475:
470:
465:
463:
459:
454:
450:
449:
440:
436:
431:
424:
422:
420:
414:
412:
408:
404:
400:
395:
391:
389:
384:
380:
375:
371:
367:
363:
359:
355:
351:
347:
343:
333:
326:
324:
322:
317:
313:
306:
304:
300:
296:
287:
282:
280:
278:
274:
270:
266:
260:
258:
253:
244:
237:
235:
233:
229:
225:
224:Bill McCollum
221:
217:
213:
209:
205:
200:
197:
193:
189:
185:
181:
177:
173:
169:
165:
161:
157:
153:
148:
147:tax avoidance
144:
139:
137:
132:
128:
120:inadmissible.
118:
113:
112:
111:
110:
109:
107:
99:
97:
95:
91:
87:
86:Chuck Schumer
82:
79:
74:
69:
67:
63:
58:
56:
52:
48:
43:
39:
34:
30:
21:
1925:. Retrieved
1921:the original
1908:
1904:
1894:
1888:H.R. 15
1883:
1872:. Retrieved
1868:the original
1858:
1847:
1836:. Retrieved
1826:
1815:. Retrieved
1809:
1799:
1788:. Retrieved
1784:
1774:
1763:. Retrieved
1759:
1717:
1705:
1676:
1670:S. 2642
1664:
1648:
1630:S. 2020
1604:
1578:
1547:
1536:. Retrieved
1531:
1518:
1502:
1437:
1426:. Retrieved
1419:the original
1414:
1402:
1391:. Retrieved
1386:
1377:
1366:. Retrieved
1361:
1352:
1341:. Retrieved
1336:
1323:
1312:. Retrieved
1308:
1298:
1287:. Retrieved
1277:
1266:. Retrieved
1256:
1245:. Retrieved
1241:
1215:. Retrieved
1209:
1185:. Retrieved
1181:
1171:
1160:. Retrieved
1155:
1151:
1124:. Retrieved
1120:
1107:
1096:. Retrieved
1093:Opinio Juris
1092:
1079:. Retrieved
1076:Opinio Juris
1075:
1065:
1054:. Retrieved
1049:
1045:
1035:
1024:. Retrieved
1019:
1015:
1006:
995:. Retrieved
989:
982:
971:. Retrieved
967:
957:
948:
944:
911:. Retrieved
892:
864:
860:
838:. Retrieved
828:
817:the original
808:
774:
731:
717:
687:George Gekas
684:
645:(D-MN) in a
588:
539:
524:as follows:
512:Conrad Burns
510:(D-NM), and
501:
483:
468:
466:
446:
444:
434:
415:
407:S. 2534
396:
392:
364:against the
339:
307:
291:
261:
249:
226:(R-FL), and
216:George Gekas
212:Howard Coble
201:
172:Kenneth Dart
140:
123:
103:
83:
70:
59:
51:income taxes
32:
28:
26:
1657:H.R. 2
1642:S. 349
1626:S. 351
1614:S. 289
736:co-founder
663:§ 2801
655:§ 877A
615:§ 2801
607:§ 877A
566:§ 2801
558:§ 877A
350:§ 6103
303:§ 6103
265:Peter Spiro
192:Sam Gibbons
1954:Categories
1927:2012-05-18
1874:2013-06-14
1838:2012-05-18
1817:2012-05-17
1790:2012-05-18
1765:2012-05-18
1739:S. 80
1610:S. 19
1538:2014-06-09
1428:2012-05-18
1393:2016-01-18
1368:2012-05-18
1343:2014-06-09
1314:2014-07-09
1289:2014-07-09
1268:2014-07-09
1247:2014-01-18
1217:2012-05-18
1187:2012-05-12
1182:Mondaq.com
1162:2012-05-18
1126:2012-05-18
1098:2014-05-09
1081:2014-06-09
1056:2012-05-18
1026:2013-01-12
997:2016-01-22
973:2014-06-09
913:2012-05-18
840:2012-05-12
787:References
580:Tom Harkin
504:Max Baucus
435:(pictured)
386:, and any
368:under the
263:professor
196:Dan Miller
164:§ 877
1733:of 2009,
1731:SAFER Act
1587:0309-7900
1242:AngloInfo
753:Bob Casey
673:SAFER Act
630:26 U.S.C.
571:26 U.S.C.
439:Roger Ver
411:tax haven
379:26 U.S.C.
238:Reactions
166:) and to
136:Jack Reed
62:Jack Reed
734:Facebook
696:8 U.S.C.
669:(D-NY).
620:8 U.S.C.
550:gift tax
548:and the
517:8 U.S.C.
506:(D-MT),
487:8 U.S.C.
312:8 U.S.C.
275:and the
222:(R-CA),
218:(R-PA),
214:(R-NC),
138:(D-RI).
127:8 U.S.C.
38:8 U.S.C.
1687:Pub. L.
1581:: 3–7.
922:of the
867:(863).
775:In the
419:removed
55:Eritrea
1917:785425
1915:
1693:
1585:
1497:, and
951:(689).
904:
873:552730
871:
698:
661:
653:
632:
622:
613:
605:
597:, and
573:
564:
556:
519:
489:
460:under
381:
348:
336:years.
314:
301:
180:Belize
162:
129:
40:
1698:(PDF)
1575:(PDF)
1528:(PDF)
1422:(PDF)
1411:(PDF)
1333:(PDF)
1148:(PDF)
1117:(PDF)
1052:(835)
820:(PDF)
813:(PDF)
771:Other
599:110th
595:109th
591:108th
356:(now
1913:SSRN
1583:ISSN
1511:2014
1507:2003
1499:2015
1495:2014
1491:2013
1487:2012
1483:2011
1479:2010
1475:2009
1471:2008
1467:2007
1463:2006
1459:2005
1455:2004
1451:2002
1447:2001
1443:2000
1158:(10)
902:ISBN
869:SSRN
657:and
627:and
609:and
560:and
202:The
194:and
27:The
1655:to
1501:",
1461:,
1020:142
374:fax
174:of
158:" (
57:.
1956::
1909:43
1907:.
1903:.
1808:.
1783:.
1758:.
1746:^
1684:,
1632:;
1616:;
1577:.
1562:^
1530:.
1493:,
1489:,
1485:,
1481:,
1477:,
1473:,
1469:,
1465:,
1457:,
1453:,
1449:,
1445:,
1413:.
1385:.
1360:.
1335:.
1307:.
1240:.
1226:^
1208:.
1196:^
1180:.
1156:41
1154:.
1150:.
1135:^
1119:.
1091:.
1074:.
1050:36
1048:.
1044:.
1018:.
1014:.
966:.
949:12
947:.
943:.
931:^
896:.
881:^
865:89
863:.
849:^
794:^
593:,
305:.
92:,
88:,
68:.
1930:.
1877:.
1841:.
1820:.
1793:.
1768:.
1741:.
1700:.
1599:.
1589:.
1541:.
1431:.
1396:.
1371:.
1346:.
1317:.
1292:.
1271:.
1250:.
1220:.
1190:.
1165:.
1129:.
1101:.
1084:.
1059:.
1029:.
1000:.
976:.
926:.
916:.
875:.
843:.
405:(
Text is available under the Creative Commons Attribution-ShareAlike License. Additional terms may apply.
