The U.S. Treasury’s latest Quarterly Publication of Individuals Who Have Chosen to Expatriate shows a sharp rise in Americans giving up their citizenship. In the second quarter of 2026, 1,781 people were listed, and combined with the 1,462 reported in the first quarter the half‑year total reached 3,243, the highest first‑half figure on record outside the pandemic‑distorted 2020 surge. At the current pace, 2026 could close with roughly 6,500 renunciations, second only to the all‑time high of 6,707 in 2020.
Recent renunciation figures
- Q2 2026: 1,781 names
- Q1 2026: 1,462 names (total 3,243 for the first half)
- Projected 2026 total: ~6,500
- Sustained quarterly average (past 2 years): ~1,360 names, the highest on record
- Annual totals:
- 2021 – 2,426
- 2022 – 3,816
- 2023 – 3,260
- 2024 – 4,819
- 2025 – 4,892
The published lists lag actual renunciations by 12–18 months on average, sometimes longer.
Limitations of the published data
- Only “covered expatriates” appear on the list:
- Net worth > $2 million, or
- Five‑year average federal tax liability > $190,000 (indexed to 2023), or
- Inability to certify five years of U.S. tax compliance before departure.
- Individuals who relinquish long‑term green‑card status or who do not meet any of the above thresholds are not recorded.
- The State Department caps the number of renunciation appointments at each diplomatic mission, and not every mission offers the service.
Expert perspectives
- David Lesperance (Lesperance & Associates) – Tracks expatriations through a quarterly “US Expatriation Index.” He argues the true number of citizens and long‑term residents giving up U.S. status is multiple times the published figures.
- Heidi Finn (Latitude Group, Denver) – Observes that most clients are seeking insurance and optionality, not immediate renunciation. Primary drivers are:
- FATCA reporting burdens
- Mortgage refusals and bank account closures for U.S. persons abroad
- Practical compliance costs rather than political ideology
- Nuri Katz (Apex Capital Partners) – Notes that high‑net‑worth individuals are largely staying in the U.S. because the exit tax on unrealized worldwide gains is prohibitive. The bulk of renunciants are “accidental Americans” who cannot afford U.S. tax compliance.
Wealthy vs. accidental Americans
- Wealthy clients: Often already file Form 8854, exceed net‑worth or tax‑liability thresholds, and therefore appear on the published list. They tend to keep U.S. citizenship, using foreign residency or second passports as a “Plan B.”
- Accidental Americans: Frequently lack the ability to file U.S. taxes, fail the five‑year compliance certification, and may not be captured by the Treasury’s list because the IRS often does not detect the missing Form 8854.
Citizenship alternatives
- Ancestry‑based citizenship is a common first step, with Ireland, Italy, Poland, and Germany offering citizenship by descent. This route does not appear in investment‑migration statistics because it requires no financial contribution.
- Where ancestry is unavailable, Caribbean citizenship‑by‑investment (CBI) programs provide rapid passports, while Portugal remains a strong option despite a 2026 extension of its naturalization timeline.
- For those who renounce but retain U.S. assets, the federal estate‑tax exclusion is $15 million in 2026 for citizens, versus a $60,000 filing threshold for non‑resident non‑citizens.
Future outlook
- Katz expects quarterly renunciation counts to fluctuate within the current range for years, as long as FATCA and U.S. tax filing remain mandatory for passport holders.
- Lesperance projects continued growth through 2028, citing factors such as:
- Proposed California wealth tax (potential federal replication)
- Political polarization and concerns about retribution
- A weakening dollar reducing the relative cost of the exit tax, a pattern reminiscent of the 2008 financial crisis.
The third‑quarter 2026 list, due later this year, will clarify whether 2026 will surpass the 2020 record.
Source article: www.imidaily.com
