Citizenship renunciation is the formal, voluntary act of giving up your citizenship in a country, typically through a documented process with a government authority. Once renounced, citizenship can't be automatically recovered; you must go through the naturalization process if you later wish to reclaim it. Renunciation is permanent unless later reversed through special legal processes.
The mechanics vary by country. In the United States, the process is codified in the Immigration and Nationality Act. A U.S. citizen seeking to renounce must appear in person before a U.S. consular officer (at a U.S. embassy or consulate abroad; U.S. citizens can't renounce on U.S. soil). The applicant must sign two forms: DS-4079 (Statement Regarding Renunciation of U.S. Nationality) and DS-4080 or DS-4081 (Oath of Renunciation of U.S. Nationality or the Renunciation Statement). The applicant must state their understanding that renunciation is permanent and that they're making the decision voluntarily without duress. The consular officer typically asks questions to confirm understanding of the consequences. Once all forms are executed, renunciation takes effect immediately, though a Certificate of Loss of Nationality is issued afterward (typically within 4–6 weeks).
The fee for U.S. renunciation is $2,350 (as of 2024), one of the highest in the world. Some view it as a deterrent to casual renunciation; others see it as an attempt to recoup government administrative costs. The UK charges approximately £372 ($470); Canada charges CAD $630 ($475); Australia charges AUD $285 (~$190). These are still significant fees, though less than the U.S.
Many European countries allow renunciation by written application to a government ministry without requiring personal appearance, particularly if you can demonstrate you're acquiring another citizenship. Timelines and documentation requirements vary widely. Some countries require proof of another citizenship before allowing renunciation; others allow renunciation even if you would be rendered stateless (though international law generally discourages this).
The primary motivation for modern renunciation is tax burden, particularly for U.S. citizens abroad. The United States' citizenship-based taxation system, combined with FATCA compliance and the burden of filing annual tax returns even when you owe little or no tax, creates significant compliance burden and potential tax liability. For Americans living abroad with substantial income or assets, renouncing U.S. citizenship and acquiring citizenship in a low-tax jurisdiction can result in substantial tax savings. This has increased U.S. renunciations: fewer than 1,000 Americans renounced citizenship annually in the early 2000s; by 2022–2024, this had increased to 6,000–8,000 annually.
A secondary motivation is the practical burden of U.S. tax compliance for Americans abroad with minimal U.S. tax liability. Filing annual Form 1040, FBAR reports, and potentially FATCA forms is time-consuming and requires hiring expensive tax professionals. For a remote worker in Portugal earning €50,000 annually, hiring a U.S. tax professional to file returns and maintain compliance may cost $2,000–$4,000 annually—a substantial burden for moderate income. This has driven renunciation even among Americans abroad who have minimal tax liability but want to eliminate the compliance burden.
Some countries require renunciation as a condition of naturalization. France, for example, has traditionally required renunciation of other nationalities when acquiring French citizenship (though this has become more flexible). An American seeking to naturalize in France might be required to renounce U.S. citizenship. This is distinct from voluntary renunciation but results in similar outcomes.
A smaller number of renunciations are motivated by political reasons—individuals renouncing citizenship as protest or because they feel disconnected from their country of citizenship. These are rare and often generate media attention (Eduardo Saverin renouncing U.S. citizenship; Tina Turner and Boris Johnson renouncing British citizenship), but they represent a small percentage of total renunciations.
The United States imposes an "exit tax" on "covered expatriates"—U.S. citizens renouncing citizenship or long-term residents abandoning residency who meet specific thresholds. A covered expatriate is broadly defined as someone with an average annual U.S. income tax liability exceeding approximately $190,000 for the five years preceding renunciation, or with a net worth exceeding $2 million at the time of renunciation. For covered expatriates, the exit tax applies.
The exit tax operates through a "mark-to-market" mechanism: all of your worldwide assets are deemed to have been sold on the renunciation date at fair market value, and any unrealized gains are taxable. This is substantial if you have appreciated assets. A person with a $5 million investment portfolio that has appreciated $2 million since acquisition faces a tax on that $2 million deemed gain, which could be $400,000–$800,000 in taxes (depending on tax brackets and deductions)—all without the individual actually selling any assets.
There are exclusions: the first $821,000 of net gain (in 2024) is excluded, and certain assets (like the primary residence, up to $750,000 of gain) are partially or fully excluded. However, for wealthy individuals with substantially appreciated assets, the exit tax can be a significant financial barrier to renunciation.
Additionally, covered expatriates must file Form 8854 (the Expatriation Statement) with their final U.S. tax return, and the IRS publishes a quarterly list of individuals who have renounced or abandoned citizenship. This public list is controversial—some view it as naming and shaming; others view it as the only means the IRS has to identify covered expatriates and ensure they pay the exit tax. Being on the list has caused controversy when published, leading to occasional calls to eliminate the public disclosure requirement.
The Reed Amendment (named after Representative Jack Reed) is a provision in the U.S. tax code that theoretically bars covered expatriates from re-entering the United States. It provides that any alien described as a covered expatriate is ineligible to receive a visa or to be admitted to the United States. In practice, this is rarely enforced, and the provision's constitutionality has been questioned. However, it technically exists and could theoretically be invoked against someone who renounced U.S. citizenship, was a covered expatriate, and did not pay the exit tax.
The practical impact is minimal—the IRS has limited resources to enforce immigration-based penalties, and the provision conflicts with other U.S. legal frameworks. However, the theoretical possibility of the Reed Amendment creates a psychological barrier for some high-net-worth Americans considering renunciation.
Beyond taxation, renunciation has other consequences. A former U.S. citizen cannot hold certain government jobs if they seek to return to the U.S., though this applies to relatively few positions. Social Security benefits may be affected (though most beneficiaries retain benefits). Health insurance tied to U.S. citizenship is lost. A renounced citizen is treated as a foreign national for immigration purposes, meaning that returning to the U.S. requires a visa, just like any other foreigner. Some renounced citizens have found themselves unable to obtain visas for travel-related purposes (certain countries scrutinize people who have renounced citizenship).
Psychological consequences are significant: renouncing citizenship is irrevocable and permanent. Individuals often describe it as severing their deepest legal tie to their country of birth. Some experience regret or loss of identity. This is why many individuals considering renunciation first acquire citizenship in another country—they want to ensure they have a legal status and travel document before giving up their original citizenship.
Several high-profile individuals have renounced U.S. citizenship, attracting media attention. Eduardo Saverin, an early Facebook investor, renounced U.S. citizenship in 2011 shortly before Facebook's IPO, a decision widely reported (and criticized) as tax-motivated. Tina Turner renounced U.S. citizenship in 1977 and acquired Swiss citizenship; she explained the decision as motivated by wanting to live permanently in Switzerland and reduce the bureaucratic burden. Boris Johnson, a U.S. citizen by birth (born in New York while his father was working there), renounced U.S. citizenship in 2023 after becoming British Prime Minister, citing the burden of FATCA compliance and embarrassment at being subject to U.S. tax while serving as UK Prime Minister.
These high-profile cases have brought attention to citizenship-based taxation and normalized renunciation in some circles, particularly among ultra-wealthy individuals and international business figures. However, renunciation remains relatively uncommon globally outside the U.S. and Eritrea, as most countries do not subject non-residents to taxation.
CBI programs frequently attract applicants motivated by renunciation planning. An individual might pursue citizenship in a Caribbean nation or Malta specifically to acquire a second passport before renouncing U.S. citizenship. This provides security (alternative citizenship is in hand before renouncing) and allows the individual to plan the renunciation strategically, timing it to align with tax years and potentially minimizing the exit tax by structuring the renunciation to occur in a lower-income year.