It is very sad that America’s tax system is so onerous that some rich people feel they have no choice but to give up U.S. citizenship in order to protect their family finances.
I’ve written about this issue before, particularly in the context of Obama’s class-warfare policies leading to an increase in the number of Americans “voting with their feet” for places with less punitive tax regimes.
We now have a very high-profile tax expatriate. One of the founders of Facebook is escaping for Singapore. Here are some relevant passages in a Bloomberg article.
Eduardo Saverin, the billionaire co- founder of Facebook Inc. (FB), renounced his U.S. citizenship before an initial public offering that values the social network at as much as $96 billion, a move that may reduce his tax bill. …Saverin’s stake is about 4 percent, according to the website Who Owns Facebook. At the high end of the IPO valuation, that would be worth about $3.84 billion. …Saverin, 30, joins a growing number of people giving up U.S. citizenship, a move that can trim their tax liabilities in that country. The Brazilian-born resident of Singapore is one of several people who helped Mark Zuckerberg start Facebook in a Harvard University dorm and stand to reap billions of dollars after the world’s largest social network holds its IPO. “Eduardo recently found it more practical to become a resident of Singapore since he plans to live there for an indefinite period of time,” said Tom Goodman, a spokesman for Saverin, in an e-mailed statement. …Singapore doesn’t have a capital gains tax. It does tax income earned in that nation, as well as “certain foreign- sourced income,” according to a government website on tax policies there. …Renouncing your citizenship well in advance of an IPO is “a very smart idea,” from a tax standpoint, said Avi-Yonah. “Once it’s public you can’t fool around with the value.” …Renouncing citizenship is an option chosen by increasing numbers of Americans. A record 1,780 gave up their U.S. passports last year compared with 235 in 2008, according to government records. …“It’s a loss for the U.S. to have many well-educated people who actually have a great deal of affection for America make that choice,” said Richard Weisman, an attorney at Baker & McKenzie in Hong Kong. “The tax cost, complexity and the traps for the unwary are among the considerations.”
What makes this story amusing, from a personal perspective, is that Saverin’s expatriation takes place just a couple of days after my wayward friend Bruce Bartlett wrote a piece for the New York Times, in which he said that people like me are exaggerating the impact of taxes on migration.
Here are some key excerpts from Bruce’s column.
In recent years, the number of Americans renouncing their citizenship has increased. …the number of Americans renouncing their citizenship rose to 1,781 in 2011 from 231 in 2008. This led William McGurn of The Wall Street Journal to warn that the tax code is turning American citizens living abroad into “economic lepers.” The sharply rising numbers of Americans renouncing their citizenship “are canaries in the coal mine,” he wrote. The economist Dan Mitchell of the libertarian Cato Institute was more explicit in a 2010 column in Forbes, “Rich Americans Voting With Their Feet to Escape Obama Tax Oppression.” …the sharp rise in Americans renouncing their citizenship since 2008 is less pronounced than it appears if one looks at the full range of data available since 1997, when it first was collected. As one can see in the chart, the highest number of Americans renouncing their citizenship came in 1997. …The reality is that taxes are just one factor among many that determine where people choose to live. Factors including climate, proximity to those in similar businesses and the availability of amenities like the arts and cuisine play a much larger role. That’s why places like New York and California are still magnets for the wealthy despite high taxes. And although a few Americans may renounce their citizenship to avoid American taxes, it is obvious that many, many more people continually seek American residency and citizenship.
I actually agree with Bruce. Taxes are just one factor when people make decisions on where to live, work, save, and invest.
But I also think Bruce is drinking too much of the Kool-Aid being served by his new friends on the left. There is a wealth of data on successful people leaving jurisdictions such as California and New York that have confiscatory tax systems.
And there’s also lots of evidence of taxpayers escaping countries controlled by politicians who get too greedy. Mr. Saverin is just the latest example. And I suspect, based on the overseas Americans I meet, that there are several people who quietly go “off the grid” for every person who officially expatriates.
The statists say these people are “tax traitors” and “economic Benedict Arnolds,” but those views are based on a quasi-totalitarian ideology that assumes government has some sort of permanent claim on people’s economic output.
If people are leaving America because our tax law is onerous, that’s a signal we should reform the tax code. Attacking those who expatriate is the fiscal version of blaming the victim.
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Great blog post Mr Mitchell,
I shared your blogpost , and the reaction of most people was that either :
– He ran away because of 0% tax rate (which patently wrong because Singapore does have 20% and 17% personal and corporate income tax).
– To people saying that it is unrellated because He could still invest in Asia.
and of course the obnoxious people claim that the government own his money.
A mixture of denial and an urge to mumble social-democratic nonsense with no regard to reality.
Excellent article. I’m an American IT manager and have spent nearly years abroad. As Petros so rightly points out the pain is being felt not only by the rich but by those of us who are strictly middle-class. And we have a distinct disadvantage compared to the wealthy in that we don’t necessarily have the funds to pay an expensive professional to stay compliant with the very onerous U.S. tax and reporting requirements. Renouncing is very much on our minds these days and it is not a decision that we take lightly. Everyone impacted by citizenship-based taxation has to do a personal cost benefit analysis. I did this recently for myself:
http://thefranco-americanflophouse.blogspot.fr/2012/05/american-citizenship-cost-benefit.html
Interestingly enough taxes (or tax compliance) are just one factor among many. Your mileage may very but, in my case, a lot has to do with wanting to be a full participant in globalization, the negative impact on my family and all the lost opportunities and outright discrimination I am experiencing because of my U.S. citizenship.
US citizenship for ordinary American ex-pats has become so carcinogenic that people are actually paying money to get rid of it.
Something has gone seriously wrong. It’s called FATCA and citizenship-based taxation. And it’s provoking an exodus.
As the implementation of FATCA approaches, the number of expatriations of American ex-pats will continue to rise.
What on earth does the US government expect when it taxes its ex-pats who have no representation in congress and receive no services from the government?
You don’t see ex-pats driving on US roads, attending US schools, using US fire, police, courts, hospitals etc. US ex-pats are not eligible for unemployment benefits or Medicare.
I seem to recall a war being fought 236 years ago over this very same issue.
Carl Levin, Charlie Rangel, Chuck Grassley need to dust off their history books and read about Lexington, Concord, Bunker Hill etc, etc and ask themselves what caused the American colonists to declare independence from Great Britain?
As William McGurn recently wrote in the WSJ:
“True, 1,800 [renunciations] is a drop in the bucket compared with either the number of Americans working abroad or the number of foreigners who are seeking U.S. citizenship. Still, when it comes to the global inefficiencies of our tax code, these 1,800 ex-Americans are canaries in the coal mine.”
In short, unless there is an about-face on citizenship-based taxation, America will lose its ex-pats.
So long to American ex-pats; so long to American exports!
The “poor” renounce by working for cash (and collect the bennies anyway), the able retire, buy tangible assets and live off tax free bonds, the rich leave and take their money with them. How long before the few tax payers who are left join the rest?
I think the majority of renunciations remain people like myself who are not extremely wealthy people who made their wealth in the United States, but just normal people living abroad who are caught in the trap that the IRS has set for the super wealthy. We want to live in freedom. So we are renouncing. I received my Certificate of Loss of Nationality in April 2012–it took over one year to get, because I informed the Consulate in Toronto on April 7, 2011, of my expatriating act. I believe the ordinary folk like me are much higher than the published numbers suggest.
The United States chases down the people like Saverin with laws like FATCA and HEART, and extra-territorial taxation, and millions of ordinary Americans living abroad will start planning their renunciation. Yes, tax policy has an effect. The US should be trying to make wealth accumulation in the United States more attractive rather than trying to chase it down when it wants to leave. Wealth goes where it is welcome. But the problem is that they try to chase it down and millions of little people are getting stomped on, little people who earned their money in countries like Canada, not in the United States.
Thanks for a great article!!
Thanks for a great article!!