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Record 2026 Expatriations Trigger Federal Register, Treasury Department IRC Section 6039G Notices

The IRS recorded 4,574 names through September, but the quarterly list tracks information received and includes some long-term residents, not just people who renounced citizenship that quarter.

At a glance

  • The all-time annual high in the figures is 6,707 names, recorded in 2020.
  • The renunciation fee fell from $2,350 to $450 on April 13.
  • A net worth of $2 million or more is one covered-expatriate test.

Reviewed November 1, 2026 Checked against the Federal Register

Status Active Currently in effect

The Internal Revenue Service listed 1,331 names in its latest quarterly expatriation notice, bringing the 2026 total through September to 4,574. The year has not set a record. Fourth-quarter figures remain outstanding.

The IRS issued the update Thursday, October 29, 2026. Its notice carries a Friday, October 30, 2026, publication date and reports information received through September 30.

Record 2026 Expatriations Trigger Federal Register, Treasury Department IRC Section 6039G Notices
Record 2026 Expatriations Trigger Federal Register, Treasury Department IRC Section 6039G Notices

The count is not a direct tally of decisions made during those months. It tracks when officials received information about a change in status.

The notice includes some long-term residents as well as former citizens

The notice covers people who lost U.S. citizenship under section 877(a) or section 877A, as well as certain long-term residents. The rules treat long-term residents under section 877(e)(2) as if they were citizens who lost citizenship, for purposes of this list.

That scope makes the headline figure broader than a count of citizens who formally renounced. The quarterly publication does not identify the precise date each person gave up citizenship or residency. It records when the government received information about the status change.

The Treasury Department's Internal Revenue Service published the notice under IRC section 6039G. Its text says the listing follows information received for the quarter ending September 30, 2026. The official notice appears at 91 FR 68602, in Volume 91, Issue 209, across pages 68602–68620.

The notice says it is published “in accordance with IRC section 6039G of the Health Insurance Portability and Accountability Act (HIPAA) of 1996, as amended.” Names run alphabetically by last name, beginning with ABBOTT, ANDREW ROBERT; ABBOTT, MATTHEW; and ABBOTT, MELANIE RAE.

Quarterly totals put 2026 below the previous annual peak so far

The first-half total was higher than the third-quarter figure. The latest 1,331 names followed 1,462 in the first quarter and 1,781 in the second.

PeriodNames listed
2026 Q11,462
2026 Q21,781
2026 Q31,331
2025 Q11,285
2025 Q21,057
2025 Q31,593
2025 Q4954

The record remains 6,707 names, recorded in 2020. The list had 5,411 names in 2016, the year Donald Trump defeated Hillary Clinton in the November election. The 2026 count now exceeds three quarters of the 2016 total, but the final quarter will determine where the year ends.

From 2000 through 2008, the annual average was 452 names, according to an analysis by Greenback Expat Tax Service. That earlier baseline is far below the recent annual totals.

The fee to renounce also changed this year. As of April 13, it fell to $450 from $2,350, a fee level reached in 2015.

Tax reporting and political unease offer different explanations for departures

One longstanding source of frustration among Americans abroad is the combination of U.S. citizenship-based taxation and foreign-account reporting. Congress passed the Foreign Account Tax Compliance Act (FATCA) in 2010; it took effect in 2014, with over 100 countries agreeing to implement it.

The law requires foreign financial institutions and certain non-financial foreign entities to report on foreign assets held by U.S. account holders. That compliance burden can affect so-called accidental Americans, people who may hold U.S. citizenship without having lived in the country or intending to do so.

Alexander Marino, who heads Moody's, described as the world's largest renunciation law practice, pointed to the reach of U.S. taxation abroad:

“No matter where you go, every euro, pound, peso you ever make is subject to U.S. tax, in life and in death. And when you're living in a low-tax jurisdiction like the United Arab Emirates, it's not fun to be taxed by the U.S.”

“And when you're living in a high-tax jurisdiction, like the U.K., having two hands in your cookie jar is also never fun”

Political discontent is another explanation offered by people considering the move. Peter Spiro, Temple University's Charles Weiner Chair in international law, said some renunciants see “a sense that America's future is increasingly problematic.” He added: “In the face of increasing political turbulence, sentimental attachment to the United States has been wearing thin”.

A former U.S. citizen living in Europe said dislike of Trump, his policies and the country's direction pushed them to “pull the trigger” on a decision they had been considering for some time.

Covered expatriate rules can add tax consequences beyond the decision itself

The IRS can classify some people who give up citizenship or long-term residency as covered expatriates. The tests include a net worth of $2 million or more, average income tax liability above $206,000 (2025) over the preceding five years, or failure to certify five years of tax compliance on Form 8854.

That certification is required for the five years before expatriation. Failing to provide it can trigger covered-expatriate status regardless of net worth or income.

Covered expatriates may face an exit tax on net unrealized gains above $890,000 (2025, inflation-adjusted) in worldwide assets under Section 877A's mark-to-market rules. Certain tax-deferred accounts, including IRAs and 401(k)s, can be treated as lump-sum distributions.

Section 2801 can also impose gift or inheritance tax at the top rate on future gifts to U.S. persons, while beneficiaries may face tax on inheritances. Renunciation is irrevocable.

Sources

Primary documents and official agency releases referenced in this story.

  1. Official source

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Nadia Hassan

Nadia Hassan covers immigration policy and legislation for VisaVerge.com, decoding the bills, executive actions, agency rule changes, and fee structures that reshape the system. With a sharp eye for how Washington's decisions reach ordinary applicants, she translates dense policy into practical context. Nadia's analysis gives readers the "what it means for you" behind every major immigration announcement.