Flott & Co. recently contacted the Department of State, suggesting that Volume 7 (Consular Affairs) of the US Department of State Foreign Affairs Manual (“FAM”) be revised. To avoid inconsistencies in the treatment of similar cases across the world by American consulates, more specific guidance and clearer procedural rules are needed for consular officers on the subject…
DetailsWhether or not one is up-to-date in their U.S. tax and reporting obligations, renunciation of U.S. citizenship may be the most sensible option in some cases. Someone who is not current can simply get themselves into compliance before beginning the renunciation process. Depending upon an individual’s income and tax situation, getting caught up on six…
DetailsThose U.S. citizens, birthright or otherwise, who wish to set their U.S. citizenship aside for whatever reason have two options: renunciation or relinquishment. Renunciation is exactly what the word implies. It is a formal sworn declaration renouncing U.S.citizenship. The procedures for renunciation are well known and straightforward. Consular Officers are generally familiar with the renunciation…
DetailsA letter (yes, an old-fashioned, sent-by-post, paper letter) arrived in my office today from an overseas lawyer seeking advice for his client. The client was born in the United States. When he was a month old, he returned with his parents to their home country, where he has now lived for more than 40 years.…
DetailsApropos being an accidental American, last week the Internal Revenue Service published a “Fact Sheet” which attempts to calm the waters upset by the widespread non-filing of US tax returns and foreign bank account reports by U.S. citizens. Quite frankly, there is very little in the Fact Sheet that is either surprising or new. Nonetheless,…
DetailsThis blog addresses how U.S. birthright citizenship and U.S. citizenship taxation affect the millions of people around the world who have American citizenship by birth or by lineage. Specifically, I focus on people who were born in the U.S., have moved abroad, are citizens by heritage, or became naturalized citizens of other countries, and live…
DetailsApril 10th, 2009 BY FAX (TOTAL OF FIVE PAGES) AND REGULAR MAIL Fax No. 202-622-5756 The Honorable Douglas H. Shulman Commissioner of Internal Revenue 1111 Constitution Ave., NW, 3000 IR Washington, DC 20224 Re: Use of Offshore Bank Accounts to Evade Tax Honorable Sir: This letter addresses an aspect of the referenced subject that has…
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